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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

Map of Xstrata's Sustainable Development (SD) Policy, SD Standards & Business Principles to External Management System Standards

This document illustrates the relationship between Xstrata's Sustainable Development (SD) Policy, SD Standards & Business Principles and the requirements of external standards as follows:

SECTION 1: Alignment map between Xstrata SD Policy, SD Standards & Business Principles to AS/NZS 4801:2001 Occupational Health and Safety Management Systems ..................................................................................................... 2 SECTION 2: Alignment map between Xstrata Sustainable Development Standards and ISO 14001: 2004 Environmental Management Systems................................................................................................................................ 21 SECTION 3: Alignment map between Xstrata SD Standards and OHSAS 18001:2007 OH&S Management Systems (UK) ....................................................................................................................................................................................... 39 SECTION 4 : Alignment map between Xstrata SD Standards and Enduring Value (2004) - The Australian Minerals Industry Framework for Sustainable Development, which provides critical guidance, at an operational level, on the ten International Council on Mining and Metals (ICMM) Sustainable Development Framework Principles ................ 56

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

SECTION 1: Alignment map between Xstrata SD Policy, SD Standards & Business Principles to AS/NZS 4801:2001 Occupational Health and Safety Management Systems

AS/NZS 4801:2001 Occupational Health and Safety Management Systems Scope This Standard specifies requirements for an occupational health and safety management system (OHSMS), to enable an organisation to formulate a policy and objectives taking into account legislative requirements and information about hazards or risks. It applies to those hazards or risks over which the organisation may exert control and over which it can be expected to have an influence. It does not state specific OHS performance outcomes. This Standard is applicable to any organisation that wishes to-- (a) implement, maintain and improve an OHSMS; (b) assure itself of its conformance with its stated OHS policy; (c) demonstrate such conformance to others; (d) seek certification/registration of its OHSMS by an external organisation; or (e) make a self-determination and declaration of conformance with the Standard. All the requirements in the Standard are intended to be incorporated into any OHSMS. The extent of the application will depend on such factors as the OHS policy of the organisation, the nature of its activities and the conditions in which it operates. Effective implementation of an OHS management system should seek to ensure the organisation complies with relevant OHS legislation, standards and codes of practice. However, the implementation of any of the requirements of this Standard, whether or not the organisation has gained certification from a third-party certification body or is otherwise recognized, does not in any way assure compliance with legal requirements, or other obligations placed upon the organisation by a statutory body. Hence, the implementation, either actual or intended, of this Standard, or parts thereof, would not preclude any action by a statutory body.

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Xstrata SD Policy ­ Health and Safety Xstrata Business Principles ­ `We Work Responsibly' SD Standard 1 Intent (Leadership, Strategy & Accountability) - Xstrata management, employees and contractors demonstrate visible sustainable development (SD) leadership, address and pursue its performance with the same priority as other key areas of business performance and understand and accept their SD accountabilities. Xstrata management develops and implements well-founded and effective SD strategies at the different levels of the organisation that reflect Xstrata's SD ambitions and commitments. Management address key SD performance issues and external factors and contributes positively to the goal of SD through an effective and integrated strategy. SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility 4.3 PLANNING 4.3.1 Planning, Identification of Hazards, Assessment & Control of Risks

AS/NZS 4801 Clauses 4.2 OHS Policy

SD Standard 5 Intent (Risk & Change Management) - Sustainable development (SD) hazards associated with Xstrata's operations, including those associated with change, are systematically identified, and, where reasonably practicable, eliminated or otherwise treated. External SD issues are identified and tracked in a timely and coordinated manner at each level of the organisation and their potential negative and/or positive consequences are understood and communicated to management at the appropriate levels. Internally created and externally imposed SD risks are incorporated into central strategy and business planning processes. SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Periodic assurance of the adequacy and effectiveness of controls Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required The development and implementation of SD incident recovery plans

SD Standard 5.2 (Risk & Change Management) - The implications of changes in Xstrata's operations, SD management and external and internal risk contexts and the ramifications in terms of risks and controls are systematically assessed as an integral part of the commodity business, division, site and project level change management processes. SD risks introduced through changes are systematically identified, analysed, evaluated and treated by the risk management processes that are required at each level of the organisation. SD Standard 5.3 (Risk & Change Management) - Appropriate mechanisms are required to monitor and review the residual SD risks that remain after the implementation of specified risk controls and treatment measures. SD Standard 11.1 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be selected based on defined sustainable development (SD) criteria which include: · A risk and performance based evaluation of their products and/or services · An evaluation of past performance SD Standard 11.3 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be engaged through a fair, formal contract or process that includes requirements for: · Meeting or exceeding the requirements in Xstrata's Business Principles, Policies, and Sustainable Development Standards when carrying out activities on or supplying to an Xstrata operation, site or project · Providing competent employees who are fit for work 4.3.2 Legal & other Requirements Xstrata SD Policy Xstrata Business Principles SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. SD Standard 7 Intent (Legal Compliance & Document Control) - Xstrata's businesses demonstrate compliance with applicable sustainable development (SD) laws, regulations, permits, standards, codes, additional requirements to which the organisation subscribes and Xstrata's SD performance requirements through an effective compliance management culture and system that includes documents, records and data control.

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 11.2 (Contractors, Suppliers & Partners) - Systems and procedures shall be established and implemented to confirm that contractors, suppliers and partners have adequate resources, systems and processes to identify and comply with applicable SD legislation, standards and codes applicable to the products or services they supply and/or their relationship with the organisation. SD Standard 11.4 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be managed through systems that include: · Documentation of responsibilities and lines of communication · Setting, monitoring and reporting on sustainable development performance targets · Monitoring and reporting on compliance with contractual SD obligations · Feedback on SD performance throughout the duration of the contract · Consequences for non-compliance 4.3.3 Objectives & Targets SD Standard 1.2 (Leadership, Strategy & Accountability) - Xstrata management creates and maintains a management culture that actively supports the achievement of Xstrata's SD objectives and commitments and the effective implementation of its SD strategies. Management makes clear the values, principles, and authority to act that each and every Xstrata employee or contractor is expected to understand and respect. Demonstrated and measurable SD leadership and management performance is a prerequisite for promotion SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans: · Align with Group, commodity business, divisional, site and project level SD strategies · Address SD risks and performance issues at the planning, design, operational and closure phases · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed · Clearly define the associated roles, responsibilities and accountabilities

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Set specific schedules and deadlines Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

SD Standard 2.3 (Planning and Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur · Take remedial actions when progress deviations occur · Revise the plan when actions fail to provide the required outcomes · Communicate progress against, and deviation from the plans to Group and commodity business level management SD Standard 10.3 (Environment, Biodiversity & Landscape Functions) - With respect to the conservation of scarce natural resources: · Systems and procedures are established and implemented to identify and document significant natural resource conservation issues, such as the use of water, energy, and raw materials · Objectives and targets are set and programme systems and procedures are established and implemented that address the priority natural resource conservation issues · The identified natural resource conservation issues are routinely reviewed and updated, in particular in light of any proposed new or modified activities and operations SD Standard 12.8 (Social & Community Engagement) - Performance is monitored on an ongoing basis, community strategies and social involvement plans are reviewed at least annually, in consultation with local communities, and actions taken where objectives and targets are not met. 4.3.4 OHS Management Plans SD Standard 2 Intent (Planning and Resources) - A formal process exists for setting annual sustainable development (SD) priorities, targets and plans at each level of the organisation that is integrated with Group business planning and risk management processes. SD priorities, targets, and plans are aligned to the appropriate strategies at each level of the organisation and are supported by adequate financial and human resources, and as necessary, specific programmes. SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans: · Align with Group, commodity business, divisional, site and project level SD strategies · Address SD risks and performance issues at the planning, design, operational and closure phases · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed · Clearly define the associated roles, responsibilities and accountabilities · Set specific schedules and deadlines · Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 2.3 (Planning and Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur · Take remedial actions when progress deviations occur · Revise the plan when actions fail to provide the required outcomes · Communicate progress against and deviation from the plans to Group and commodity business level management SD Standard 16 Intent (Monitoring and Review) - Through the ongoing monitoring of sustainable development (SD) performance and routine management reviews, the adequacy and effectiveness of SD strategies, plans, systems, programmes and processes are routinely assessed and actions are taken to address weaknesses and share good performance across the organisation. SD Standard 16.3 (Monitoring and Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy, and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up.

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses 4.4 IMPLEMENTATION 4.4.1 Structure & Responsibility Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

Xstrata Business Principles ­ `We work responsibly' SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understand s and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility. SD Standard 1.6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, documented and communicated: · Roles, responsibilities and accountabilities are allocated for specific SD risks and controls · Specific and measurable SD performance indicators · SD organisational structures and lines of reporting SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans: · Align with Group, commodity business, divisional, site and project level SD strategies · Address SD risks and performance issues at the planning, design, operational and closure phases · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed · Clearly define the associated roles, responsibilities and accountabilities · Set specific schedules and deadlines · Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

4.4.1.1 Resources

Xstrata Business Principles ­ `We work responsibly' SD Standard 2 Intent (Planning and Resources) - A formal process exists for setting annual sustainable development (SD) priorities, targets and plans at each level of the organisation that is integrated with Group business planning and risk management processes. SD priorities, targets, and plans are aligned to the appropriate strategies at each level of the organisation and are supported by adequate financial and human resources, and, as necessary, specific programmes. SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans:

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Align with Group, commodity business, divisional, site and project level SD strategies Address SD risks and performance issues at the planning, design, operational and closure phases Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed Clearly define the associated roles, responsibilities and accountabilities Set specific schedules and deadlines Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

SD Standard 2.4 (Planning and Resources) - SD programmes are developed and implemented at the appropriate level of the organisation when additional resources and focus are needed to address a specific SD performance issue or risk. 4.4.1.2 Responsibility & Accountability Xstrata Business Principles ­ `We work ethically', `We work responsibly' SD Standard 1 Intent (Leadership, Strategy & Accountability) - Xstrata management, employees and contractors demonstrate visible sustainable development (SD) leadership, address and pursue its performance with the same priority as other key areas of business performance and understand and accept their SD accountabilities. Xstrata management develops and implements well-founded and effective SD strategies at the different levels of the organisation that reflect Xstrata's SD ambitions and commitments. Management addresses key SD performance issues and external factors and contributes positively to the goal of SD through an effective and integrated strategy. SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 1. 6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, documented and communicated: · Roles, responsibilities and accountabilities are allocated for specific SD risks and controls · Specific and measurable SD performance indicators · SD organisational structures and lines of reporting 4.4.2 Training, Awareness and Competence Xstrata Business Principles - 'We work responsibly' SD Standard 3 Intent (Behaviour, Awareness & Competency) - Management, employees and contractors have the necessary awareness, commitment and competency to perform their

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles work activities and make operational and business decisions in accordance with Xstrata's delegated authority levels and sustainable development (SD) framework. All employees and contractors behave in accordance with Xstrata's Business Principles and Sustainable Development Policy commitments. SD Standard 3.1 (Behaviour, Awareness & Competency) - SD competency is achieved through: · Identifying the SD competencies required for all manager, employee and contractor positions and roles · The assessment of SD competency and awareness as a key selection criteria · Applicable induction processes that address Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards and specific SD requirements · The establishment and maintenance of specific SD training plans for all positions and roles, including training in SD management systems · The identification and provision of appropriate competency-based SD training for all positions and roles · The ongoing assessment of SD competence and the provision of SD refresher training as required The application of these requirements is appropriate to the SD obligations and the SD hazards associated with the work activities. SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility · Adequate financial resources to ensure the integrity of critical plant, equipment and structures · Sourcing specialist advice and support as required · Employee and contractor involvement · Hazard identification through hazard analysis, assessment and prioritisation · Identification and recording of all critical plant, equipment, structures and processes · Documented operating and safe work procedures · Permit to work systems · Competent operations and maintenance employees and contractors · Availability of appropriate operational safety information · Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems · Inspection and testing prior to commissioning new or re-introduced plant and equipment. · Documenting design parameters of plant and equipment · Monitoring and reviewing design parameters as applicable · Plant and equipment operators working within design parameters · Timely availability, quality and suitability of consumables and replacement parts · Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 10.8 (Environment, Biodiversity & Land Functions) - Appropriate education and awareness about the environment, biodiversity and landscape function is provided to relevant personnel using specialist advice as required. SD Standard 17.3 (Emergencies, Crises & Business Continuity) - All employees and non-employees are trained in the emergency response plan to understand: · Their roles and responsibilities · The use of emergency response resources 4.4.3 Consultation, Communication & Reporting 4.4.3.1 Consultation

Xstrata SD Policy ­ `Our People' SD Standard 15.1 (Incident Management) ­ Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis · Developing, implementing and monitoring the effectiveness of corrective and preventative actions · Documentation and communication of the changes resulting from the investigation and root cause analysis findings · Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group · Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses SD Standard 15.4 (Incident Management) - Commodity business executive teams demonstrate their personal involvement in the management of a critical HSEC incident through an executive team member: · Communicating directly with site personnel · Reviewing the investigation process, findings and recommendations · Supporting the capture of incident-related learning and its communication within the commodity business, where appropriate across the organisation and/or

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AS/NZS 4801 Clauses with external stakeholders 4.4.3.2 Communication Xstrata SD Policy ­ ` Our People' Xstrata Business Principles ­ ` We work openly' SD Standard 4.3 (Communication & Engagement) - Xstrata management communicates, engages and consults with employees and external stakeholders in the development, implementation and review of SD requirements and in the identification and assessment of SD risks. SD Standard 4.4 (Communication & Engagement) - Relevant SD experience and knowledge is shared across Xstrata sites and with appropriate external stakeholders, including evolving health, safety, environmental and community development knowledge regarding Xstrata's operations, activities and products. SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of Xstrata's: · SD objectives, strategies, plans, targets, requirements and any recent changes to these · SD performance, risks and other SD matters An independently verified Group Sustainability Report that meets international reporting standards is published annually and is supplemented by sustainability reports at a commodity business, division, site or project level as appropriate. Each report communicates with identified stakeholder groups. SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and non-governmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. SD Standard 5.1 (Risk and Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system 4.4.3.3 Reporting Xstrata Business Principles ­ ` We work openly' SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community (HSEC) incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up. 4.4.4 Documentation SD Standard 7.3 (Legal Compliance & Document Control) - The structure of SD management frameworks, systems and related documentation is defined SD Standard 15.1 (Incident Management) ­ Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include:

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · · · · · · · · · 4.4.5 Document and Data Control Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Immediate response to incidents Recording, classifying and reporting of incidents Relevant statutory notifications Media relations plans where required Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis Developing, implementing and monitoring the effectiveness of corrective and preventative actions Documentation and communication of the changes resulting from the investigation and root cause analysis findings Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

SD Standard 7.4 (Legal Compliance & Document Control) - There is a SD document control process that manages: · Management system(s) documentation through revisions and approvals · Relevant legislation, standards, codes, and requirements · The removal of obsolete documentation · The traceability, confidentiality and archiving of essential data and records

4.4.6 Hazard Identification, Risk Assessment & Control of Risks 4.4.6.2 Hazard Identification

Xstrata SD Policy ­ `Our People' SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies Periodic assurance of the adequacy and effectiveness of controls Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required The development and implementation of SD incident recovery plans

SD Standard 9.2 (Health & Occupational Hygiene) - Occupational health and hygiene systems, plans, programmes and controls are established and implemented to: · Identify occupational health and hygiene hazards including those associated with all work environments and activities · Assess employee and contractor exposure to the hazards with reference to internationally recognised monitoring standards · Eliminate as far as reasonably practicable, or otherwise minimise exposure to, hazards · Provide personal protective equipment where other controls do not effectively reduce the risks · Drive continuous improvements in occupational health and hygiene 4.4.6.3 Risk Assessment SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 5.2 (Risk & Change Management) - The implications of changes in Xstrata's operations, SD management and external and internal risk contexts and the ramifications in terms of risks and controls are systematically assessed as an integral part of the commodity business, division, site and project level change management processes. SD risks introduced through changes are systematically identified, analysed, evaluated and treated by the risk management processes that are required at each level of the organisation SD Standard 9.2 (Health & Occupational Hygiene) - Occupational health and hygiene systems, plans, programmes and controls are established and implemented to: · Identify occupational health and hygiene hazards including those associated with all work environments and activities

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Assess employee and contractor exposure to the hazards with reference to internationally recognised monitoring standards Eliminate as far as reasonably practicable, or otherwise minimise exposure to, hazards Provide personal protective equipment where other controls do not effectively reduce the risks Drive continuous improvements in occupational health and hygiene

SD Standard 14. 1 (Product Stewardship) - Systems, processes and procedures exist to: · Assess existing and new products and services for their SD benefits, impacts and risks over their life cycle · Identify opportunities to conduct or support research and innovation that leads to the development of products and technologies that have lower SD impacts and risks 4.4.6.4 Risk Control SD Standard 5.1 (Risk & Change Management) -The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 5.2 (Risk & Change Management) - The implications of changes in Xstrata's operations, SD management and external and internal risk contexts and the ramifications in terms of risks and controls are systematically assessed as an integral part of the commodity business, division, site and project level change management processes. SD risks introduced through changes are systematically identified, analysed, evaluated and treated by the risk management processes that are required at each level of the organisation SD Standard 9.2 (Health & Occupational Hygiene) - Occupational health and hygiene systems, plans, programmes and controls are established and implemented to: · Identify occupational health and hygiene hazards including those associated with all work environments and activities · Assess employee and contractor exposure to the hazards with reference to internationally recognised monitoring standards · Eliminate as far as reasonably practicable, or otherwise minimise exposure to, hazards · Provide personal protective equipment where other controls do not effectively reduce the risks

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · 4.4.7 Emergency Preparedness & Response Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Drive continuous improvements in occupational health and hygiene

Xstrata SD Policy ­ ` Health & Safety' SD Standard 17 Intent (Emergencies, Crises & Business Continuity) - To provide appropriate resources and effective emergency response, business continuity and crisis management planning structures to manage site and project health, safety, environment and community (HSEC) emergencies and commodity business HSEC crises. SD Standard 17.1 (Emergencies, Crises & Business Continuity) - Foreseeable site and project HSEC emergencies and business HSEC crises are systematically identified and their HSEC impacts assessed, including those associated with activities adjacent to sites and projects. SD Standard 17.5 (Emergencies, Crises & Business Continuity) - Emergency response, crisis management and business continuity plan exercises are conducted: · At least annually and as scheduled · With involvement from external emergency agencies, as appropriate · To review the completeness and currency of the HSEC emergency and crisis scenarios considered in site and project planning SD Standard 17.6 (Emergencies, Crises & Business Continuity) - Lessons learnt from the success and failures of actual emergencies and of emergency exercises are: · Developed from systematic root cause analysis · Properly documented · Used to review and amend existing plans and resources as required · Shared amongst other Xstrata operations as appropriate

4.5 MEASUREMENT & EVALUATION 4.5.1.1 Monitoring & Measurement General

SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility · SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · · · · · · · · · · · · · · · 4.5.1.2 Health Surveillance Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Adequate financial resources to ensure the integrity of critical plant, equipment and structures. Sourcing specialist advice and support as required Employee and contractor involvement Hazard identification through hazard analysis, assessment and prioritisation Identification and recording of all critical plant, equipment, structures and processes Documented operating and safe work procedures Permit to work systems Competent operations and maintenance employees and contractors Availability of appropriate operational safety information Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems Inspection and testing prior to commissioning new or re-introduced plant and equipment. Documenting design parameters of plant and equipment Monitoring and reviewing design parameters as applicable Plant and equipment operators working within design parameters Timely availability, quality and suitability of consumables and replacement parts Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment

SD Standard 9.1 (Health & Occupational Hygiene) - Occupational health assessment and surveillance systems and plans are established and implemented that include: · Pre-employment health assessments that establish a baseline position and assess fitness for work · Regular health surveillance appropriate to the level of exposure · Communication of the results of health assessments and surveillance with due regard for confidentiality SD Standard 15.1 (Incident Management) ­ Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis · Developing, implementing and monitoring the effectiveness of corrective and preventative actions

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4.5.2 Incident Investigation, Corrective & Preventative Action

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Documentation and communication of the changes resulting from the investigation and root cause analysis findings Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

4.5.3 Records & Records Management

SD Standard 7.4 (Legal Compliance & Document Control) - There is a SD document control process that manages: · Management system(s) documentation through revisions and approvals · Relevant legislation, standards, codes, and requirements · The removal of obsolete documentation · The traceability, confidentiality and archiving of essential data and records SD Standard 16.1 (Monitoring & Review) - Processes are established and implemented so that SD performance is routinely measured, monitored, recorded, assessed and acted upon by management. This includes SD inspections and audits conducted by commodity businesses and sites at frequencies appropriate to their SD risks and performance. SD Standard 16.2 (Monitoring & Review) - Commodity businesses, sites and projects comply with Group and commodity business sustainable development assurance programmes. Non-conformances are addressed and the implementation and adequacy of corrective actions are tracked and assessed. SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up.

4.5.4 OHSMS Audits

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SECTION 1: ALIGNMENT OF XSTRATA SD POLICY, SD STANDARDS & BUSINESS PRINCIPLES TO AS/NZS 4801:2001

AS/NZS 4801 Clauses 4.6 Management Review Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 2.3 (Planning and Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur · Take remedial actions when progress deviations occur · Revise the plan when actions fail to provide the required outcomes · Communicate progress against and deviation from the plans to Group and commodity business level management SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up.

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

SECTION 2: Alignment map between Xstrata Sustainable Development Standards and ISO 14001:2004 Environmental Management Systems

ISO 14001:2004 specifies requirements for an environmental management system to enable an organisation to develop and implement a policy and objectives which take into account legal requirements and other requirements to which the organisation subscribes, and information about significant environmental aspects. It applies to those environmental aspects that the organisation identifies as those which it can control and those which it can influence. It does not itself state specific environmental performance criteria. ISO 14001:2004 is applicable to any organisation that wishes to establish, implement, maintain and improve an environmental management system, to assure itself of conformity with its stated environmental policy, and to demonstrate conformity with ISO 14001:2004 by a) making a self-determination and self-declaration, or b) seeking confirmation of its conformance by parties having an interest in the organisation, such as customers, or c) seeking confirmation of its self-declaration by a party external to the organisation, or d) seeking certification/registration of its environmental management system by an external organisation. All the requirements in ISO 14001:2004 are intended to be incorporated into any environmental management system. The extent of the application will depend on factors such as the environmental policy of the organisation, the nature of its activities, products and services and the location where and the conditions in which it functions.

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses 4.1 General Requirements 4.2 Environmental Policy Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Xstrata SD Policy Xstrata Business Principles ­ `We Work Responsibly' Xstrata SD Policy SD Standard 1 Intent (Leadership, Strategy & Accountability) - Xstrata management, employees and contractors demonstrate visible sustainable development (SD) leadership, address and pursue its performance with the same priority as other key areas of business performance and understand and accept their SD accountabilities. Xstrata management develops and implements well-founded and effective SD strategies at the different levels of the organisation that reflect Xstrata's SD ambitions and commitments. Management address key SD performance issues and external factors and contribute positively to the goal of SD through an effective and integrated strategy. SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: · Consider and address current and anticipated SD risks, in particular: o business opportunities o issues and trends at the global, regional and local levels o discrete and aggregated risks and impacts of our activities, operations, and projects across the life cycle · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate · Reflect consultation with relevant internal and external stakeholders · Are documented and communicated to all appropriate levels within the commodity businesses; and · Are reviewed for continued effectiveness and updated annually. SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses 4.3 PLANNING 4.3.1 Environmental Aspects Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 5 Intent (Risk & Change Management) - Sustainable development (SD) hazards associated with Xstrata's operations, including those associated with change, are systematically identified and, where reasonably practicable, eliminated or otherwise treated. External SD issues are identified and tracked in a timely and coordinated manner at each level of the organisation and their potential negative and/or positive consequences are understood and communicated to management at the appropriate levels. Internally created and externally imposed SD risks are incorporated into central strategy and business planning processes. SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 5.2 (Risk & Change Management) - The implications of changes in Xstrata's operations, SD management and external and internal risk contexts and the ramifications in terms of risks and controls are systematically assessed as an integral part of the commodity business, division, site and project level change management processes. SD risks introduced through changes are systematically identified, analysed, evaluated and treated by the risk management processes that are required at each level of the organisation SD Standard 5.3 (Risk & Change Management) - Appropriate mechanisms are required to monitor and review the residual SD risks that remain after the implementation of specified risk controls and treatment measures. SD Standard 10.1 (Environment, Biodiversity & Land Functions) - Systems and procedures are established and implemented to: · Identify and document all aspects of site and project operations and activities that impact, or could potentially impact, the natural environment including air, surface and groundwater, land, habitats, biodiversity and landscape functions (e.g. watershed management, control of soil erosion, and the creation of microclimates). · Conduct environmental baseline surveys and environmental impact assessments at appropriate points in the project or operating life cycle · Assess the aspects and identify significant and potential impacts that require priority attention and management and establish plans, programmes and targets as appropriate · Routinely review and update identified aspects when there have been significant changes or new developments to site and project operations and activities

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 11.1 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be selected based on defined sustainable development (SD) criteria which include: · A risk and performance based evaluation of their products and/or services · An evaluation of their past performance SD Standard 14.1 (Product Stewardship) - Systems, processes and procedures exist to: · Assess existing and new products and services for their SD benefits, impacts and risks over their life cycle · Identify opportunities to conduct or support research and innovation that leads to the development of products and technologies that have lower SD impacts and risks 4.3.2 Legal & other Requirements Xstrata Business Principles ­ ``We work ethically' SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 7.2 (Legal Compliance & Document Control) - In countries or regions where HSEC legislation is below Xstrata's standards then Xstrata's SD framework will set the minimum level of acceptable HSEC performance 4.3.3 Objectives, Targets and Programme(s) SD Standard 1.2 (Leadership, Strategy & Accountability) - Xstrata management creates and maintains a management culture that actively supports the achievement of Xstrata's SD objectives and commitments and the effective implementation of its SD strategies. Management makes clear the values, principles, and authority to act that each and every Xstrata employee or contractor is expected to understand and respect. Demonstrated and measurable SD leadership and management performance is a prerequisite for promotion. SD Standard 1.3 (Leadership, Strategy & Accountability) -Xstrata management develops and implements well-founded and effective SD strategies at different levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: · Consider and address current and anticipated SD risks, in particular: o business opportunities o issues and trends at the global, regional and local levels o discrete and aggregated risks and impacts of our activities, operations, and projects across the life cycle · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate · Reflect consultation with relevant internal and external stakeholders · Are documented and communicated to all appropriate levels within the commodity businesses; and · Are reviewed for continued effectiveness and updated annually. SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 1.5 (Leadership, Strategy & Accountability) - The specific and measurable SD goals, action and targets for each executive, manager and employee are included in performance plans and form an essential part of individual performance appraisals. SD Standard 2 Intent (Planning and Resources) - A formal process exists for setting annual sustainable development (SD) priorities, targets and plans at each level of the organisation that is integrated with Group business planning and risk management processes. SD priorities, targets, and plans are aligned to the appropriate strategies at each level of the organisation and are supported by adequate financial and human resources and, as necessary, specific programmes. SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 16.1 (Monitoring & Review) - Processes are established and implemented so that SD performance is routinely measured, monitored, recorded, assessed and acted upon by management. This includes SD inspections and audits conducted by commodity businesses and sites at frequencies appropriate to their SD risks and performance. 4.4 IMPLEMENTATION & OPERATION 4.4.1 Resources, Roles, Responsibilities and Authority

SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 1.5 (Leadership, Strategy & Accountability) - The specific and measurable SD goals, actions, and targets for each executive, manager and employee are included in performance plans and form an essential part of individual performance appraisal. SD Standard 1.6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, documented and communicated: Roles, responsibilities and accountabilities are allocated for specific SD risks and controls Specific and measurable SD performance indicators SD organisational structures and lines of reporting SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans: · Align with Group, commodity business, divisional, site and project level SD strategies · Address SD risks and performance issues at the planning, design, operational and closure phases · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed · Clearly define the associated roles, responsibilities and accountabilities · Set specific schedules and deadlines · Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 3.2 (Behaviour, Awareness & Competency) - Employees and contractors are made aware of their obligations to: · Understand and comply with Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards · Participate in the development and implementation of SD management systems · Comply with defined SD procedures · Advise management of changes to the work environment that could affect SD risk levels and/or SD performance 4.4.2 Competence, Training and Awareness SD Standard 3 Intent (Behaviour, Awareness & Competency) - Management, employees and contractors have the necessary awareness, commitment and competency to perform their work activities and make operational and business decisions in accordance with Xstrata's delegated authority levels and sustainable development (SD) framework. All employees and contractors behave in accordance with Xstrata's Business Principles and Sustainable Development Policy commitments. SD Standard 3.1 (Behaviour, Awareness & Competency) - SD competency is achieved through: · Identifying the SD competencies required for all manager, employee and contractor positions and roles · The assessment of SD competency and awareness as a key selection criteria · Applicable induction processes that address Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards and specific SD requirements · The establishment and maintenance of specific SD training plans for all positions and roles, including training in SD management systems · The identification and provision of appropriate competency-based SD training for all positions and roles · The ongoing assessment of SD competence and the provision of SD refresher training as required SD Standard 5.2 (Risk & Change Management) - The implications of changes in Xstrata's operations, SD management and external and internal risk contexts and the ramifications in terms of risks and controls are systematically assessed as an integral part of the commodity business, division, site and project level change management processes. SD risks introduced through changes are systematically identified, analysed, evaluated and treated by the risk management processes that are required at each level of the organisation SD Standard 14.2 (Product Stewardship) - All relevant employees, contractors, customers and other relevant internal and external stakeholders are appropriately informed of the SD hazards associated with the handling, transport, use, storage and disposal of Xstrata's products. 4.4.3 Communication SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: · Consider and address current and anticipated SD risks, in particular: o business opportunities o issues and trends at the global, regional and local levels o discrete and aggregated risks and impacts of our activities, operations, and projects across the life cycle

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate Reflect consultation with relevant internal and external stakeholders Are documented and communicated to all appropriate levels within the commodity businesses; and Are reviewed for continued effectiveness and updated annually.

SD Standard 4 Intent (Communication & Engagement) - Effective and timely internal communication and consultation occurs at and between the different levels of the organisation about sustainable development (SD) expectations, risks, performance, leading practice, and other issues. Communication and engagement with employees across the Group continuously improves SD awareness, commitment and competency. Proactive communication and engagement occurs with external stakeholders who are concerned with, or affected by, Xstrata's SD performance. Communication is conducted in an equitable and culturally sensitive manner with the maximum transparency that is commercially possible. SD Standard 4.2 (Communication & Engagement) - Equitable and culturally appropriate processes are implemented and maintained to engage external stakeholders in respect of their SD concerns and expectations with regard to Xstrata's operations, activities and products SD Standard 4.3 (Communication & Engagement) - Xstrata management communicate, engage and consult with employees and external stakeholders in the development, implementation and review of SD requirements and in the identification and assessment of SD risks. SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of Xstrata's: · SD objectives, strategies, plans, targets and requirements, and any recent changes to these · SD performance, risks and other SD matters An independently verified Group Sustainability Report that meets international reporting standards is published annually and is supplemented by sustainability reports at a commodity business, division, site or project level as appropriate. Each report communicates with identified stakeholder groups. SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and non-governmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. SD Standard 5 Intent (Risk & Change Management) - Sustainable development (SD) hazards associated with Xstrata's operations, including those associated with change, are systematically identified and, where reasonably practicable, eliminated or otherwise treated. External SD issues are identified and tracked in a timely and coordinated manner at each level of the organisation and their potential negative and/or positive consequences are understood and communicated to management at the appropriate levels. Internally created and externally imposed SD risks are incorporated into central strategy and business planning processes. SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through:

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses · · · · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles The development, implementation and continual improvement of systematic SD risk management processes and procedures Systematic identification of SD hazards and external issues associated with Xstrata's operations The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies Recording of SD risks in defined registers which are reviewed at least annually Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies Periodic assurance of the adequacy and effectiveness of controls Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required The development and implementation of SD incident recovery plans

SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 15.1 (Incident Management) ­ Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis · Developing, implementing and monitoring the effectiveness of corrective and preventative actions · Documentation and communication of the changes resulting from the investigation and root cause analysis findings · Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles and high potential HSEC incidents within commodity businesses and across the Xstrata Group Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

SD Standard 15.2 (Incident Management) - Xstrata plc Board and Group Executive Committee are informed of all critical and high potential HSEC incidents in a timely and accurate manner. SD Standard 15.3 (Incident Management) - Commodity business boards or executive teams are provided with the following for all critical and high potential HSEC incidents: · Notification of the incident · Management of the incident · Outcomes of the investigation · Completion of corrective actions 4.4.4 Documentation SD Standard 7 Intent (Legal Compliance & Document Control) - Xstrata's businesses demonstrate compliance with applicable sustainable development (SD) laws, regulations, permits, standards, codes, additional requirements to which the organisation subscribes and Xstrata's SD performance requirements through an effective compliance management culture and system that includes documents, records and data control. SD Standard 7.3 (Legal Compliance & Document Control) - The structure of SD management frameworks, systems and related documentation is defined SD Standard 7.4 (Legal Compliance & Document Control) - There is a SD document control process that manages: · Management system(s) documentation through revisions and approvals · Relevant legislation, standards, codes, and requirements · The removal of obsolete documentation · The traceability, confidentiality and archiving of essential data and records SD Standard 10.1 (Environment, Biodiversity & Land Functions) - Systems and procedures are established and implemented to: · Identify and document all aspects of site and project operations and activities that impact, or could potentially impact, the natural environment including air, surface and groundwater, land, habitats, biodiversity and landscape functions (e.g. watershed management, control of soil erosion, and the creation of microclimates). · Conduct environmental baseline surveys and environmental impact assessments at appropriate points in the project or operating life cycle · Assess the aspects and identify significant and potential impacts that require priority attention and management and establish plans, programmes and targets as appropriate · Routinely review and update identified aspects when there have been significant changes or new developments to site and project operations and activities

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ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

4.4.5 Control of Documents

SD Standard 7 Intent (Legal Compliance & Document Control) - Xstrata's businesses demonstrate compliance with applicable sustainable development (SD) laws, regulations, permits, standards, codes, additional requirements to which the organisation subscribes and Xstrata's SD performance requirements through an effective compliance management culture and system that includes documents, records and data control. SD Standard 7.4 (Legal Compliance & Document Control) - There is a SD document control process that manages: · Management system(s) documentation through revisions and approvals · Relevant legislation, standards, codes, and requirements · The removal of obsolete documentation · The traceability, confidentiality and archiving of essential data and records

4.4.6 Operational Control

SD Standard 5 Intent (Risk & Change Management) - Sustainable development (SD) hazards associated with Xstrata's operations, including those associated with change, are systematically identified and, where reasonably practicable, eliminated or otherwise treated. External SD issues are identified and tracked in a timely and coordinated manner at each level of the organisation and their potential negative and/or positive consequences are understood and communicated to management at the appropriate levels. Internally created and externally imposed SD risks are incorporated into central strategy and business planning processes. SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses · · · · · · · · · · · · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Adequate financial resources to ensure the integrity of critical plant, equipment and structures. Sourcing specialist advice and support as required Employee and contractor involvement Hazard identification through hazard analysis, assessment and prioritisation Identification and recording of all critical plant, equipment, structures and processes Documented operating and safe work procedures Permit to work systems Competent operations and maintenance employees and contractors Availability of appropriate operational safety information Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems Inspection and testing prior to commissioning new or re-introduced plant and equipment. Documenting design parameters of plant and equipment Monitoring and reviewing design parameters as applicable Plant and equipment operators working within design parameters Timely availability, quality and suitability of consumables and replacement parts Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment

SD Standard 10.1 (Environment, Biodiversity & Land Functions) - Systems and procedures are established and implemented to: · Identify and document all aspects of site and project operations and activities that impact, or could potentially impact, the natural environment including air, surface and groundwater, land, habitats, biodiversity and landscape functions (e.g. watershed management, control of soil erosion, and the creation of microclimates). · Conduct environmental baseline surveys and environmental impact assessments at appropriate points in the project or operating life cycle · Assess the aspects and identify significant and potential impacts that require priority attention and management and establish plans, programmes and targets as appropriate · Routinely review and update identified aspects when there have been significant changes or new developments to site and project operations and activities SD Standard 11.1 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be selected based on defined sustainable development (SD) criteria which include: · A risk and performance based evaluation of their products and/or services · An evaluation of their past performance SD Standard 14.1 (Product Stewardship) - Systems, processes and procedures exist to: · Assess existing and new products and services for their SD benefits, impacts and risks over their life cycle · Identify opportunities to conduct or support research and innovation that leads to the development of products and technologies that have lower SD impacts and risk

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses 4.4.7 Emergency Preparedness & Response Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 17 Intent (Emergencies, Crises & Business Continuity) - To provide appropriate resources and effective emergency response, business continuity and crisis management planning structures to manage site and project health, safety, environment and community (HSEC) emergencies and commodity business HSEC crises. SD Standard 17.2 (Emergencies, Crises & Business Continuity) - Site and project emergency response and business continuity plans are developed in consultation with external emergency agencies to mitigate the assessed HSEC impacts and restore the business. These plans are: · Documented with defined roles and responsibilities · Communicated throughout the site or project · Made accessible to everyone at site or at the project · Maintained and updated through periodic testing SD Standard 17.3 (Emergencies, Crises & Business Continuity) - All employees and non-employees are trained in the emergency response plan to understand: · Their roles and responsibilities · The use of emergency response resources SD Standard 17.5 (Emergencies, Crises & Business Continuity) - Emergency response, crisis management and business continuity plan exercises are conducted: · At least annually and as scheduled · With involvement from external emergency agencies, as appropriate · To review the completeness and currency of the HSEC emergency and crisis scenarios considered in site and project planning SD Standard 17.6 (Emergencies, Crises & Business Continuity - )Lessons learnt from the success and failures of actual emergencies and of emergency exercises are: · Developed from systematic root cause analysis · Properly documented · Used to review and amend existing plans and resources as required Shared amongst other Xstrata operations as appropriate SD Standard 17.7 (Emergencies, Crises & Business Continuity) - Site and project emergency response plans are aligned to a commodity business level crisis management plan 4.5 CHECKING 4.5.1 Monitoring & Measurement

SD Standard 8.2 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is confirmed by: · Reviewing the effectiveness of inspection, testing and maintenance activities and procedures · Reviewing the effectiveness of failure and incident analysis and the associated corrective actions · Periodic operational integrity audits

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 10.1 (Environment, Biodiversity & Land Functions) - Systems and procedures are established and implemented to: · Identify and document all aspects of site and project operations and activities that impact, or could potentially impact, the natural environment including air, surface and groundwater, land, habitats, biodiversity and landscape functions (e.g. watershed management, control of soil erosion, and the creation of microclimates). · Conduct environmental baseline surveys and environmental impact assessments at appropriate points in the project or operating life cycle · Assess the aspects and identify significant and potential impacts that require priority attention and management and establish plans, programmes and targets as appropriate · Routinely review and update identified aspects when there have been significant changes or new developments to site and project operations and activities SD Standard 14.1 (Product Stewardship) - Systems, processes and procedures exist to: · Assess existing and new products and services for their SD benefits, impacts and risks over their life cycle · Identify opportunities to conduct or support research and innovation that leads to the development of products and technologies that have lower SD impacts and risks SD Standard 14.4 (Product Stewardship) - Systems and procedures exist to identify, evaluate and respond to changes in external legal and other sustainable development requirements that have potential impacts on Xstrata's products and/or operations SD Standard 15.1 (Incident Management) - Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis · Developing, implementing and monitoring the effectiveness of corrective and preventative actions · Documentation and communication of the changes resulting from the investigation and root cause analysis findings · Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group · Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses 4.5.2 Evaluation of Compliance Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 7 Intent - Xstrata's businesses demonstrate compliance with applicable sustainable development (SD) laws, regulations, permits, standards, codes, additional requirements to which the organisation subscribes and Xstrata's SD performance requirements through an effective compliance management culture and system that includes documents, records and data control. SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 7.2 (Legal Compliance & Document Control) - In countries or regions where HSEC legislation is below Xstrata's standards then Xstrata's SD framework will set the minimum level of acceptable HSEC performance SD Standard 15.1 (Incident Management) - Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis · Developing, implementing and monitoring the effectiveness of corrective and preventative actions · Documentation and communication of the changes resulting from the investigation and root cause analysis findings · Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group · Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses 4.5.3 Non-conformity, Corrective Action and Preventative Action Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 15.1 (Incident Management) - Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis · Developing, implementing and monitoring the effectiveness of corrective and preventative actions · Documentation and communication of the changes resulting from the investigation and root cause analysis findings · Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group · Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses SD Standard 16.2 (Monitoring & Review) - Commodity businesses, sites and projects comply with Group and commodity business sustainable development assurance programmes. Non-conformances are addressed and the implementation and adequacy of corrective actions are tracked and assessed 4.5.4 Control of Records SD Standard 7 (Legal Compliance & Document Control) - Xstrata's businesses demonstrate compliance with applicable sustainable development (SD) laws, regulations, permits, standards, codes, additional requirements to which the organisation subscribes and Xstrata's SD performance requirements through an effective compliance management culture and system that includes documents, records and data control. SD Standard 7.3 (Legal Compliance & Document Control) - The structure of SD management frameworks, systems and related documentation is defined SD Standard 7.4 (Legal Compliance & Document Control) - There is a SD document control process that manages: · Management system(s) documentation through revisions and approvals · Relevant legislation, standards, codes, and requirements · The removal of obsolete documentation · The traceability, confidentiality and archiving of essential data and records 4.5.5 Internal Audit

SD Standard 16.1 (Monitoring & Review) - Processes are established and implemented so that SD performance is routinely measured, monitored, recorded, assessed and acted upon by management. This includes SD inspections and audits conducted by commodity businesses and sites at frequencies appropriate to their SD risks and performance.

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 16.2 (Monitoring & Review) - Commodity businesses, sites and projects comply with Group and commodity business sustainable development assurance programmes. Non-conformances are addressed and the implementation and adequacy of corrective actions are tracked and assessed. SD Standard 16.4 (Monitoring & Review) - The Group and commodity business level Sustainable Development Policies and Sustainable Development Standards are reviewed at least every three years and revised as required. 4.6 Management Review SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 2.3 (Planning & Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur · Take remedial actions when progress deviations occur · Revise the plan when actions fail to provide the required outcomes · Communicate progress against, and deviation from the plans to Group and commodity business level management SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety. Environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments

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SECTION 2: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES WITH ISO 14001

ISO 14001 - Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up.

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

SECTION 3: Alignment map between Xstrata SD Standards and OHSAS 18001:2007 OH&S Management Systems (UK)

OHSAS 18001:2007 Occupational health and safety management systems This Occupational Health and Safety Assessment Series (OHSAS) specification gives requirements for an occupational health and safety (OH&S) management system, to enable an organisation to control its OH&S risks and improve its OH&S performance. It does not state specific OH&S performance criteria, nor does it give detailed specifications for the design of a management system. This OHSAS specification is applicable to any organisation that wishes to:

·

Establish an OH&S management system to eliminate or minimize risks to personnel and other interested parties who could be exposed to OH&S hazards associated with its activities · Implement, maintain and continually improve an OH&S management system · Assure itself of its conformity with this OH&S policy · Demonstrate such conformity with this OHSAS Standard by: o Making a self-determination and self-declaration, or o Seeking confirmation of its conformance by parties having an interest in the organisation, such as customers, or o Seeking confirmation of its self-declaration by a party external to the organisation, or o Seeking certification/registration of its OH&S management system by an external organisation. All the requirements in this OHSAS specification are intended to be incorporated into any OH&S management system. The extent of the application will depend on such factors as the OH&S policy of the organisation, the nature of its activities and the risks and complexity of its operations. This OHSAS Standard is intended to address occupational health and safety, and is not intended to address other health and safety areas such as employee wellbeing/wellness programmes, product safety, property damage or environmental impacts.

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses 4.2 OHS Policy Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Xstrata SD Policy ­ Health and Safety Xstrata Business Principles ­ `We Work Responsibly' SD Standard I Intent (Leadership, Strategy & Accountability) - Xstrata management, employees and contractors demonstrate visible sustainable development (SD) leadership, address and pursue its performance with the same priority as other key areas of business performance and understand and accept their SD accountabilities. Xstrata management develops and implements well-founded and effective SD strategies at the different levels of the organisation that reflect Xstrata's SD ambitions and commitments. Management address key SD performance issues and external factors and contribute positively to the goal of SD through an effective and integrated strategy. SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 1.5 (Leadership, Strategy & Accountability) - The specific and measurable SD goals, actions and targets for each executive, manager and employee are included in performance plans and form an essential part of individual performance appraisal. SD Standard 1.6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, documented and communicated: Roles, responsibilities and accountabilities are allocated for specific SD risks and controls Specific and measurable SD performance indicators SD organisational structures and lines of reporting

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OHSAS 18001 Clauses 4.3 PLANNING 4.3.1 Hazard Identification, Risk Assessment & Determining Controls Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

SD Standard 5 Intent (Risk & Change Management) - Sustainable development (SD) hazards associated with Xstrata's operations, including those associated with change, are systematically identified and, where reasonably practicable, eliminated or otherwise treated. External SD issues are identified and tracked in a timely and coordinated manner at each level of the organisation and their potential negative and/or positive consequences are understood and communicated to management at the appropriate levels. Internally created and externally imposed SD risks are incorporated into central strategy and business planning processes. SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 5.2 (Risk & Change Management) - The implications of changes in Xstrata's operations, SD management and external and internal risk contexts and the ramifications in terms of risks and controls are systematically assessed as an integral part of the commodity business, division, site and project level change management processes. SD risks introduced through changes are systematically identified, analysed, evaluated and treated by the risk management processes that are required at each level of the organisation SD Standard 5.3 (Risk & Change Management) - Appropriate mechanisms are required to monitor and review the residual SD risks that remain after the implementation of specified risk controls and treatment measures. SD Standard 11.1 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be selected based on defined sustainable development (SD) criteria which include:

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OHSAS 18001 Clauses · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles A risk and performance based evaluation of their products and/or services An evaluation of their past performance

SD Standard 11.3 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be engaged through a fair, formal contract or process that includes requirements for: · Meeting or exceeding the requirements in Xstrata's Business Principles, Policies and Sustainable Development Standards when carrying out activities on or supplying to an Xstrata operation, site or project · Providing competent employees who are fit for work 4.3.2 Legal & other Requirements Xstrata SD Policy Xstrata Business Principles ­ `We work together and with others SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. SD Standard 7 Intent (Legal Compliance & Document Control) - Xstrata's businesses demonstrate compliance with applicable sustainable development (SD) laws, regulations, permits, standards, codes, additional requirements to which the organisation subscribes and Xstrata's SD performance requirements through an effective compliance management culture and system that includes documents, records and data control. SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 11.2 Contractors, Suppliers & Partners) - Systems and procedures shall be established and implemented to confirm that contractors, suppliers and

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles partners have adequate resources, systems and processes to identify and comply with applicable SD legislation, standards and codes applicable to the products or services they supply and/or their relationship with the organisation. SD Standard 11.4 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be managed through systems that include: · Documentation of responsibilities and lines of communication · Setting, monitoring and reporting on sustainable development performance targets · Monitoring and reporting on compliance with contractual SD obligations · Feedback on SD performance throughout the duration of the contract · Consequences for non-compliance 4.3.3 Objectives & programmes SD Standard 1.2 (Leadership, Strategy & Accountability) - Xstrata management creates and maintains a management culture that actively supports the achievement of Xstrata's SD objectives and commitments and the effective implementation of its SD strategies. Management makes clear the values, principles, and authority to act that each and every Xstrata employee or contractor is expected to understand and respect. Demonstrated and measurable SD leadership and management performance is a prerequisite for promotion SD Standard 2 Intent (Planning & Resources) - A formal process exists for setting annual sustainable development (SD) priorities, targets and plans at each level of the organisation that is integrated with Group business planning and risk management processes. SD priorities, targets, and plans are aligned to the appropriate strategies at each level of the organisation and are supported by adequate financial and human resources and, as necessary, specific programmes. SD Standard 2.1(Planning & Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans: · Align with Group, commodity business, divisional, site and project level SD strategies · Address SD risks and performance issues at the planning, design, operational and closure phases · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed · Clearly define the associated roles, responsibilities and accountabilities · Set specific schedules and deadlines · Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels SD Standard 2.3 (Planning & Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur

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OHSAS 18001 Clauses · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Take remedial actions when progress deviations occur Revise the plan when actions fail to provide the required outcomes Communicate progress against, and deviation from the plans to Group and commodity business level management

SD Standard 10.3 (Environment, Biodiversity & Land Functions) - With respect to the conservation of scarce natural resources: · Systems and procedures are established and implemented to identify and document significant natural resource conservation issues, such as the use of water, energy, and raw materials · Objectives and targets are set and programme systems and procedures are established and implemented that address the priority natural resource conservation issues · The identified natural resource conservation issues are routinely reviewed and updated, in particular in light of any proposed new or modified activities and operations SD Standard 12.8 (Social & Community Engagement) - Performance is monitored on an ongoing basis, community strategies and social involvement plans are reviewed at least annually, in consultation with local communities, and actions taken where objectives and targets are not met. SD Standard 16 Intent (Monitoring & Review) - Through the ongoing monitoring of sustainable development (SD) performance and routine management reviews, the adequacy and effectiveness of SD strategies, plans, systems, programmes and processes are routinely assessed and actions are taken to address weaknesses and share good performance across the organisation. SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments, and new scientific findings and technological developments and new scientific

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles findings and technological developments. The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up. 4.4 IMPLEMENTATION & OPERATION 4.4.1 Resources, roles, responsibility, accountability and authority

Xstrata Business Principles ­ `We work responsibly' SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 1.6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, documented and communicated: · Roles, responsibilities and accountabilities are allocated for specific SD risks and controls · Specific and measurable SD performance indicators · SD organisational structures and lines of reporting SD Standard 2.1 (Planning & Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans: · Align with Group, commodity business, divisional, site and project level SD strategies · Address SD risks and performance issues at the planning, design, operational and closure phases · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed · Clearly define the associated roles, responsibilities and accountabilities · Set specific schedules and deadlines · Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

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OHSAS 18001 Clauses 4.4.2 Competence, Training and Awareness Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Xstrata Business Principles ­ `We work responsibly' SD Standard 3 Intent (Behaviour, Awareness & Competency) - Management, employees and contractors have the necessary awareness, commitment and competency to perform their work activities and make operational and business decisions in accordance with Xstrata's delegated authority levels and sustainable development (SD) framework. All employees and contractors behave in accordance with Xstrata's Business Principles and Sustainable Development Policy commitments. SD Standard 3.1 (Behaviour, Awareness & Competency) - SD competency is achieved through: · Identifying the SD competencies required for all manager, employee and contractor positions and roles · The assessment of SD competency and awareness as a key selection criteria · Applicable induction processes that address Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards and specific SD requirements · The establishment and maintenance of specific SD training plans for all positions and roles, including training in SD management systems · The identification and provision of appropriate competency-based SD training for all positions and roles · The ongoing assessment of SD competence and the provision of SD refresher training as required The application of these requirements is appropriate to the SD obligations and the SD hazards associated with the work activities. SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility · Adequate financial resources to ensure the integrity of critical plant, equipment and structures. · Sourcing specialist advice and support as required · Employee and contractor involvement · Hazard identification through hazard analysis, assessment and prioritisation · Identification and recording of all critical plant, equipment, structures and processes · Documented operating and safe work procedures · Permit to work systems · Competent operations and maintenance employees and contractors · Availability of appropriate operational safety information · Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems · Inspection and testing prior to commissioning new or re-introduced plant and equipment. · Documenting design parameters of plant and equipment

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Monitoring and reviewing design parameters as applicable Plant and equipment operators working within design parameters Timely availability, quality and suitability of consumables and replacement parts Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment

SD Standard 10.8 (Environment, Biodiversity & Land Functions) - Appropriate education and awareness about the environment, biodiversity and landscape function is provided to relevant personnel using specialist advice as required. SD Standard 17.3 (Environment, Biodiversity & Land Functions) - All employees and non-employees are trained in the emergency response plan to understand: · Their roles and responsibilities · The use of emergency response resources 4.4.3 Communication, Participation and Consultation Xstrata SD Policy ­ `Our People' SD Standard 4.3 (Communication & Engagement) - Xstrata management communicates, engages and consults with employees and external stakeholders in the development, implementation and review of SD requirements and in the identification and assessment of SD risks. SD Standard 4.4 (Communication & Engagement) - Relevant SD experience and knowledge is shared across Xstrata sites and with appropriate external stakeholders, including evolving health, safety, environmental and community development knowledge regarding Xstrata's operations, activities and products. SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of Xstrata's: · SD objectives, strategies, plans, targets, requirements and any recent changes to these · SD performance, risks and other SD matters An independently verified Group Sustainability Report that meets international reporting standards is published annually and is supplemented by sustainability reports at a commodity business, division, site or project level as appropriate. Each report communicates with identified stakeholder groups. SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and non-governmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. SD Standard 15.1 (Incident Management) ­ Health, safety, environment and community (HSEC )incident management systems are developed and implemented that

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses include: · · · · · · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

Immediate response to incidents Recording, classifying and reporting of incidents Relevant statutory notifications Media relations plans where required Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis Developing, implementing and monitoring the effectiveness of corrective and preventative actions Documentation and communication of the changes resulting from the investigation and root cause analysis findings Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

SD Standard 15.4 (Incident Management) - Commodity business executive teams demonstrate their personal involvement in the management of a critical HSEC incident through an executive team member: · Communicating directly with site personnel · Reviewing the investigation process, findings and recommendations · Supporting the capture of incident-related learning and its communication within the commodity business, where appropriate across the organisation and/or with external stakeholders 4.4.4 Documentation SD Standard 7.3 (Legal Compliance & Document Control) - The structure of SD management frameworks, systems and related documentation is defined SD Standard 15.1 (Incident Management) ­ Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic

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OHSAS 18001 Clauses · · · · 4.4.5 Control of Documents Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles root cause analysis Developing, implementing and monitoring the effectiveness of corrective and preventative actions Documentation and communication of the changes resulting from the investigation and root cause analysis findings Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

SD Standard 7.4 (Legal Compliance & Document Control) - There is a SD document control process that manages: · Management system(s) documentation through revisions and approvals · Relevant legislation, standards, codes, and requirements · The removal of obsolete documentation · The traceability, confidentiality and archiving of essential data and records Xstrata SD Policy ­ `Our People' SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility

4.4.6 Operational Control

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OHSAS 18001 Clauses · · · · · · · · · · · · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Adequate financial resources to ensure the integrity of critical plant, equipment and structures. Sourcing specialist advice and support as required Employee and contractor involvement Hazard identification through hazard analysis, assessment and prioritisation Identification and recording of all critical plant, equipment, structures and processes Documented operating and safe work procedures Permit to work systems Competent operations and maintenance employees and contractors Availability of appropriate operational safety information Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems Inspection and testing prior to commissioning new or re-introduced plant and equipment. Documenting design parameters of plant and equipment Monitoring and reviewing design parameters as applicable Plant and equipment operators working within design parameters Timely availability, quality and suitability of consumables and replacement parts Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment

SD Standard 8.2 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is confirmed by: · Reviewing the effectiveness of inspection, testing and maintenance activities and procedures · Reviewing the effectiveness of failure and incident analysis and the associated corrective actions · Periodic operational integrity audits SD Standard 11.3 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be engaged through a fair, formal contract or process that includes requirements for: · Meeting or exceeding the requirements in Xstrata's Business Principles, Policies and Sustainable Development Standards when carrying out activities on or supplying to an Xstrata operation, site or project · Providing competent employees who are fit for work SD Standard 11.4 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be managed through systems that include: · Documentation of responsibilities and lines of communication · Setting, monitoring and reporting on sustainable development performance targets

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OHSAS 18001 Clauses · · · 4.4.7 Emergency Preparedness & Response Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Monitoring and reporting on compliance with contractual SD obligations Feedback on SD performance throughout the duration of the contract Consequences for non-compliance

Xstrata SD Policy ­ ` Health & Safety' SD Standard 17 Intent (Emergencies, Crises & Business Continuity) - To provide appropriate resources and effective emergency response, business continuity and crisis management planning structures to manage site and project health, safety, environment and community (HSEC) emergencies and commodity business HSEC crises. SD Standard 17.1 (Emergencies, Crises & Business Continuity) - Foreseeable site and project HSEC emergencies and business HSEC crises are systematically identified and their HSEC impacts assessed, including those associated with activities adjacent to sites and projects SD Standard 17.5 (Emergencies, Crises & Business Continuity) - Emergency response, crisis management and business continuity plan exercises are conducted: · At least annually and as scheduled · With involvement from external emergency agencies, as appropriate · To review the completeness and currency of the HSEC emergency and crisis scenarios considered in site and project planning SD Standard 17.6 (Emergencies, Crises & Business Continuity) - Lessons learnt from the success and failures of actual emergencies and of emergency exercises are: Developed from systematic root cause analysis Properly documented Used to review and amend existing plans and resources as required Shared amongst other Xstrata operations as appropriate

4.5 CHECKING 4.5.1 Performance, Measurement & Monitoring

SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles The development, implementation and continuous improvement of SD systems within each manager's area of responsibility

SD Standard 1.6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, documented and communicated: · Roles, responsibilities and accountabilities are allocated for specific SD risks and controls · Specific and measurable SD performance indicators · SD organisational structures and lines of reporting SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility · Adequate financial resources to ensure the integrity of critical plant, equipment and structures. · Sourcing specialist advice and support as required · Employee and contractor involvement · Hazard identification through hazard analysis, assessment and prioritisation · Identification and recording of all critical plant, equipment, structures and processes · Documented operating and safe work procedures · Permit to work systems · Competent operations and maintenance employees and contractors · Availability of appropriate operational safety information · Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems · Inspection and testing prior to commissioning new or re-introduced plant and equipment. · Documenting design parameters of plant and equipment · Monitoring and reviewing design parameters as applicable · Plant and equipment operators working within design parameters · Timely availability, quality and suitability of consumables and replacement parts · Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment SD Standard 9.2 (Health & Occupational Hygiene) - Occupational health and hygiene systems, plans, programmes and controls are established and implemented to: · Identify occupational health and hygiene hazards including those associated with all work environments and activities · Assess employee and contractor exposure to the hazards with reference to internationally recognised monitoring standards

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses · · · 4.5.2 Evaluation of compliance Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Eliminate as far as reasonably practicable, or otherwise minimise exposure to, hazards Provide personal protective equipment where other controls do not effectively reduce the risks Drive continuous improvements in occupational health and hygiene

SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 15.1 (Incident Management) - Health, safety, environment and community (HSEC) incident management systems are developed and implemented that include: · Immediate response to incidents · Recording, classifying and reporting of incidents · Relevant statutory notifications · Media relations plans where required · Incident investigation conducted to a depth commensurate with the actual and/or potential consequence of the incident · Establishing the direct and underlying causes and contributing factors and identifying the lessons learnt through the adoption of appropriate and systematic root cause analysis · Developing, implementing and monitoring the effectiveness of corrective and preventative actions · Documentation and communication of the changes resulting from the investigation and root cause analysis findings · Documentation and communication of lessons learnt from incident investigations to relevant employees and contractors within the business; and for all critical and high potential HSEC incidents within commodity businesses and across the Xstrata Group · Collation and analysis of HSEC incident and investigation data to identify trends, assess the effectiveness of current SD management and where necessary initiate appropriate responses

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4.5.3 Incident Investigation, Nonconformity, Corrective Action & Preventative Action

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SECTION 3: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO OHSAS 18001:2007 OH&S MANAGEMENT SYSTEMS (UK)

OHSAS 18001 Clauses 4.5.4 Control of Records Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 7.3 (Legal Compliance & Document Control) - The structure of SD management frameworks, systems and related documentation is defined SD Standard 7.4 (Legal Compliance & Document Control) - There is a SD document control process that manages: · Management system(s) documentation through revisions and approvals · Relevant legislation, standards, codes, and requirements · The removal of obsolete documentation · The traceability, confidentiality and archiving of essential data and records 4.5.5 Internal Audits SD Standard 16.1 (Monitoring & Review) - Processes are established and implemented so that SD performance is routinely measured, monitored, recorded, assessed and acted upon by management. This includes SD inspections and audits conducted by commodity businesses and sites at frequencies appropriate to their SD risks and performance. SD Standard 16.2 (Monitoring & Review) - Commodity businesses, sites and projects comply with Group and commodity business sustainable development assurance programmes. Non-conformances are addressed and the implementation and adequacy of corrective actions are tracked and assessed. SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up.

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OHSAS 18001 Clauses 4.6 Management Review Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 1.4 (Leadership, Strategy & Accountability) - Management understands and accepts its responsibilities and accountabilities, which include: · Understanding and meeting the intent and expectations of Xstrata's Group Business Principles, Policies, Sustainable Development Standards and applicable regulations · Identifying, analysing, evaluating and treating SD risks and opportunities at the commodity business, division, site and project level · The SD performance of each manager's area of responsibility · The development, implementation and continuous improvement of SD systems within each manager's area of responsibility SD Standard 2.3 (Planning & Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur · Take remedial actions when progress deviations occur · Revise the plan when actions fail to provide the required outcomes · Communicate progress against, and deviation from the plans to Group and commodity business level management SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up.

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SECTION 4: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO ENDURING VALUE (2004)

SECTION 4 : Alignment map between Xstrata SD Standards and Enduring Value (2004) - The Australian Minerals Industry Framework for Sustainable Development, which provides critical guidance, at an operational level, on the ten International Council on Mining and Metals (ICMM) Sustainable Development Framework Principles

Enduring Value ­ The Australian Minerals Industry Framework for Sustainable Development (2004) The Minerals Council of Australia has launched the first framework, globally, for translating sustainable development principles into site-based performance in the Australian minerals industry. Enduring Value provides critical guidance on ethical business practices, the integration of sustainable development in corporate decision-making, human rights and cultural awareness, risk management based on sound science, continuous improvement in safety and health and environmental performance, conservation of biodiversity, materials stewardship, economic and social development and effective community engagement. Member companies of the Minerals Council of Australia have endorsed Enduring Value as a condition of MCA membership. The framework ·

Aligns with global industry initiatives, and in particular provides critical guidance on the International Council on Mining and Metals (ICMM) Sustainable Development Framework Principles and their application at the operational level; Builds on the Australian Minerals Industry Code for Environmental Management - the platform for industry's continual improvement in managing environmental issues since its introduction in 1996; Provides a vehicle for industry differentiation and leadership, building reputational capital with the community, government and the finance and insurance sectors; and

·

·

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·

Assists the industry to operate in a manner which is attuned to the expectations of the community, and which seeks to maximise the long-term benefits to society that can be achieved through the effective management of Australia's natural resources.

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Enduring Value Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Principle/Element PRINCIPAL 1 ­ IMPLEMENT AND MAINTAIN EHTICAL BUSINESS PARTNERS AND SOUND SYSTME OF CORPORATE GOVERNANCE Xstrata SD Policy ­ Health and Safety · Element 1.1 Develop and Xstrata Business Principles ­ `We work ethically', `We work responsibly', We work openly' implement company statements of ethical SD Standard 1 Intent (Leadership, Strategy & Accountability) - Xstrata management, employees and contractors demonstrate visible sustainable development (SD) business principles leadership, address and pursue its performance with the same priority as other key areas of business performance and understand and accept their SD accountabilities. Xstrata management develops and implements well-founded and effective SD strategies at the different levels of the organisation that reflect Xstrata's SD ambitions and and practices that commitments. Management address key SD performance issues and external factors and contribute positively to the goal of SD through an effective and integrated management is strategy. committed to enforcing SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. · Element 1.2 Implement policies SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different and practices that levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively seek to prevent to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and bribery and implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: corruption · Consider and address current and anticipated SD risks, in particular: o business opportunities · Element 1.3 o issues and trends at the global, regional and local levels Comply with or o discrete and aggregated risks an d impacts of our activities, operations, and projects across the life cycle exceed the · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate requirements of host · Reflect consultation with relevant internal and external stakeholders country laws and · Are documented and communicated to all appropriate levels within the commodity businesses; and regulations · Are reviewed for continued effectiveness and updated annually. · Element 1.4 SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in Work withy consultation with employees and other relevant internal and external stakeholders. SD plans: governments, · Align with Group, commodity business, divisional, site and project level SD strategies industry and other · Address SD risks and performance issues at the planning, design, operational and closure phases stakeholders to achieve appropriate · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed and effective public · Clearly define the associated roles, responsibilities and accountabilities

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Enduring Value Principle/Element policy, laws, regulations and procedures that facilitate the mining, minerals and metals sector's contribution to sustainable development within national sustainable development strategies Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles · · Set specific schedules and deadlines Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

SD Standard 2.3 (Planning and Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur · Take remedial actions when progress deviations occur · Revise the plan when actions fail to provide the required outcomes · Communicate progress against and deviation from the plans to Group and commodity business level management SD Standard 3.2 (Behaviour, Awareness & Competency) - Employees and contractors are made aware of their obligations to: · Understand and comply with Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards · Participate in the development and implementation of SD management systems · Comply with defined SD procedures · Advise management of changes to the work environment that could affect SD risk levels and/or SD performance SD Standard 4.2 (Communication & Engagement) - Equitable and culturally appropriate processes are implemented and maintained to engage external stakeholders in respect of their SD concerns and expectations with regard to Xstrata's operations, activities and products. SD Standard 4.3 (Communication & Engagement) - Xstrata management communicates, engages and consults with employees and external stakeholders in the development, implementation and review of SD requirements and in the identification and assessment of SD risks. SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of Xstrata's: · SD objectives, strategies, plans, targets, requirements and any recent changes to these · SD performance, risks and other SD matters SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and nongovernmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives.

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Enduring Value Principle/Element Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC) legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 7.2 (Legal Compliance & Document Control) - In countries or regions where HSEC legislation is below Xstrata's standards then Xstrata's SD framework will set the minimum level of acceptable HSEC performance SD Standard 11.3 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be engaged through a fair, formal contract or process that includes requirements for: · Meeting or exceeding the requirements in Xstrata's Business Principles, Policies and Sustainable Development Standards when carrying out activities on or supplying to an Xstrata operation, site or project · Providing competent employees who are fit for work SD Standard 14.1 (Product Stewardship) - Systems, processes and procedures exist to: · Assess existing and new products and services for their SD benefits, impacts and risks over their life cycle · Identify opportunities to conduct or support research and innovation that leads to the development of products and technologies that have lower SD impacts and risks SD Standard 14.3 (Product Stewardship) - Strategies are implemented that support research and innovation aimed at improving the safe use and recycling of our products and developing technologies for extracting and processing metals and minerals that are efficient in the use of energy, natural resources and materials.

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Enduring Value Principle/Element Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

PRINCIPLE 2 - INTEGRATE SUSTAINABLE DEVELOPMENT CONSIDERATIONS WITHIN THE CORPORATE DECISION-MAKING PROCESS Xstrata SD Policy ­ Health and Safety · Element 2.1 Integrate sustainable Xstrata Business Principles ­ `We work ethically', `We work responsibly', We work openly' development principles into SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to company policies meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. and practices SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively · Element 2.2 to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and Plan, design, operate implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: and close operations · Consider and address current and anticipated SD risks, in particular: in a manner that o business opportunities enhances sustainable o issues and trends at the global, regional and local levels development o discrete and aggregated risks an d impacts of our activities, operations, and projects across the life cycle · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate · Element 2.3 · Reflect consultation with relevant internal and external stakeholders Implement good · Are documented and communicated to all appropriate levels within the commodity businesses; and practice and innovate to improve · Are reviewed for continued effectiveness and updated annually. social, environmental and economic SD Standard 2 Intent (Planning and Resources) - A formal process exists for setting annual sustainable development (SD) priorities, targets and plans at each level of the organisation that is integrated with Group business planning and risk management processes. SD priorities, targets, and plans are aligned to the appropriate strategies performance whilst at each level of the organisation and are supported by adequate financial and human resources and, as necessary, specific programmes. enhancing shareholder value. SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in consultation with employees and other relevant internal and external stakeholders. SD plans: · Element 2.4 · Align with Group, commodity business, divisional, site and project level SD strategies Encourage customers, business · Address SD risks and performance issues at the planning, design, operational and closure phases partners and supplier · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed of good and services · Clearly define the associated roles, responsibilities and accountabilities to adopt principles · Set specific schedules and deadlines

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Enduring Value Principle/Element and practices that are comparable to our own · Element 2.5 Provide sustainable development training to ensure adequate competency at all levels among our employees and those of our contractors · Element 2.6 Support public policies that foster open and competitive markets Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles · Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

SD Standard 2.3 (Planning and Resources) - Annual SD plans are reviewed at least quarterly to: · Check progress against the plan's objectives, targets and timelines · Update the plans when changes to business circumstances occur · Take remedial actions when progress deviations occur · Revise the plan when actions fail to provide the required outcomes · Communicate progress against, and deviation from the plans to Group and commodity business level management SD Standard 3.1 (Behaviour, Awareness & Competency) - SD competency is achieved through: · Identifying the SD competencies required for all manager, employee and contractor positions and roles · The assessment of SD competency and awareness as a key selection criteria · Applicable induction processes that address Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards and specific SD requirements · The establishment and maintenance of specific SD training plans for all positions and roles, including training in SD management systems · The identification and provision of appropriate competency-based SD training for all positions and roles · The ongoing assessment of SD competence and the provision of SD refresher training as required The application of these requirements is appropriate to the SD obligations and the SD hazards associated with the work activities. SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and nongovernmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. SD Standard 10.1 (Environment, Biodiversity & Land Functions) - Systems and procedures are established and implemented to: · Identify and document all aspects of site and project operations and activities that impact, or could potentially impact, the natural environment including air, surface and groundwater, land, habitats, biodiversity and landscape functions (e.g. watershed management, control of soil erosion, and the creation of microclimates). · Conduct environmental baseline surveys and environmental impact assessments at appropriate points in the project or operating life cycle · Assess the aspects and identify significant and potential impacts that require priority attention and management and establish plans, programmes and targets as appropriate

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Enduring Value Principle/Element · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Routinely review and update identified aspects when there have been significant changes or new developments to site and project operations and activities

SD Standard 11.1 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be selected based on defined sustainable development (SD) criteria which include: · A risk and performance based evaluation of their products and/or services · An evaluation of their past performance SD Standard 11.2 (Contractors, Suppliers & Partners) - Systems and procedures shall be established and implemented to confirm that contractors, suppliers and partners have adequate resources, systems and processes to identify and comply with applicable SD legislation, standards and codes applicable to the products or services they supply and/or their relationship with the organisation. SD Standard 11.3 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be engaged through a fair, formal contract or process that includes requirements for: · Meeting or exceeding the requirements in Xstrata's Business Principles, Policies and Sustainable Development Standards when carrying out activities on or supplying to an Xstrata operation, site or project · Providing competent employees who are fit for work SD Standard 11.4 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be managed through systems that include: · Documentation of responsibilities and lines of communication · Setting, monitoring and reporting on sustainable development performance targets · Monitoring and reporting on compliance with contractual SD obligations · Feedback on SD performance throughout the duration of the contract · Consequences for non-compliance SD Standard 11.5 (Contractors, Suppliers & Partners) - Demonstrable processes shall exist to create business opportunities for local contractors, suppliers and partners that: · Do not compromise Xstrata's Sustainable Development Standards · Contribute to sustainable community development SD Standard 11.6 (Contractors, Suppliers & Partners) - Procurement of products and services supports positive sustainability outcomes through the supply chain. SD Standard 13.1 (Life Cycle Management ­ Projects & Operations) - SD risks of new developments are identified, analysed, evaluated and treated by processes that include: · An appropriate level of baseline SD assessments prior to commencing exploration or construction activities · Pre-feasibility studies that identify any fundamental SD impediments, the completion of sufficiently detailed and robust social, health and environmental impact

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Enduring Value Principle/Element · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles assessments and land-use assessments to determine the associated risks to be treated should the project proceed The development and implementation of appropriate SD risk management strategies that meet Xstrata, commodity business, statutory and stakeholder requirements A mechanism to ensure the transfer of knowledge concerning SD risks and their management, between each phase of the project life cycle A phase by phase process designed and implemented to ensure that as new SD and operational information and knowledge is acquired, it is used to review and test the assumptions made at earlier phases of the project life cycle A mechanism to ensure, when appropriate, the transfer of knowledge concerning SD risks and their management, to other projects being implemented by Xstrata The identification assessment and management of property rights that considers: land, tenure, cultural heritage, authority to access and the level of community support.

SD Standard 13.4 (Life Cycle Management ­ Projects & Operations) - Closure Plans are developed, maintained, and implemented as designed, for all operations and are: · Compliant with Xstrata's Business Principles, Policies, Sustainable Development Standards, all applicable regulatory obligations, and international standards regarding mine closure including financial provisioning requirements. · Based on a robust process developed at the commodity business level for identifying and assessing all significant SD risks and controls. This includes commercial opportunities to share risks with other parties and the associated costs related to the foreseen decommissioning, closure, rehabilitation and postclosure obligations and activities · Annually reviewed, including a review of assumptions and cost-estimates, to address any changes in circumstances such as changes in legal requirements, new technologies, the local environmental and community situation etc · Developed and reviewed by appropriately experienced and competent persons including external experts, as necessary SD Standard 16 Intent (Monitoring and Review) - Through the ongoing monitoring of sustainable development (SD)performance and routine management reviews, the adequacy and effectiveness of SD strategies, plans, systems, programmes and processes are routinely assessed and actions are taken to address weaknesses and share good performance across the organisation.

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Enduring Value Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Principle/Element PRINCIPLE 3 ­ UPHOLD FUNDAMENTAL HUMAN RIGHTS AND RESPECT CULTURES, CUSTOMES AND VALUES IN DEALINGS WITH EMPLOYEES AND OTHERS WHO ARE AFFECTED BY OUR ACTIVITIES Xstrata SD Policy · Element 3.1 Ensure faire Xstrata Business Principles remuneration and work conditions for SD Standard 1.1 (Leadership, Strategy & Accountability) - Management, employees and contractors demonstrate visible, proactive leadership and commitment to all employees and do meeting Xstrata's SD ambitions and commitments, as expressed in Xstrata's Business Principles and Sustainable Development Policy. not use forced, compulsory or child SD Standard 1.6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, labour documented and communicated: · Roles, responsibilities and accountabilities are allocated for specific SD risks and controls · Element 3.2 · Specific and measurable SD performance indicators Provide for the · SD organisational structures and lines of reporting constructive engagement of SD Standard 3.1 (Behaviour, Awareness & Competency) - SD competency is achieved through: employees on · Identifying the SD competencies required for all manager, employee and contractor positions and roles matters of mutual · The assessment of SD competency and awareness as a key selection criteria concern · Applicable induction processes that address Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards and specific SD requirements · Element 3.3 · The establishment and maintenance of specific SD training plans for all positions and roles, including training in SD management systems Implement policies · The identification and provision of appropriate competency-based SD training for all positions and roles and practices · The ongoing assessment of SD competence and the provision of SD refresher training as required designed to eliminate The application of these requirements is appropriate to the SD obligations and the SD hazards associated with the work activities. harassment and unfair discrimination SD Standard 4 Intent (Communication & Engagement) - Effective and timely internal communication and consultation occurs at and between the different levels of in all aspects of our the organisation about sustainable development (SD) expectations, risks, performance, leading practice, and other issues. Communication and engagement with activities employees across the Group continuously improves SD awareness, commitment and competency. Proactive communication and engagement occurs with external stakeholders who are concerned with, or affected by, Xstrata's SD performance. Communication is conducted in an equitable and culturally sensitive manner with the · Element 3.4 maximum transparency that is commercially possible. Ensue that all relevant staff,

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Enduring Value Principle/Element including security personnel, are provided with appropriate cultural and human rights training and guidance. · Element 3.5 Minimise involuntary resettlement, and compensate fairly for adverse effects on the community where this cannot be avoided · Element 3.6 Respect the culture and heritage of local communities, including indigenous peoples Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 4.2 (Communication & Engagement) - Equitable and culturally appropriate processes are implemented and maintained to engage external stakeholders in respect of their SD concerns and expectations with regard to Xstrata's operations, activities and products SD Standard 4.3 (Communication & Engagement) - Xstrata management communicates, engages and consults with employees and external stakeholders in the development, implementation and review of SD requirements and in the identification and assessment of SD risks. SD Standard 4.7 (Communication & Engagement) - An employee grievance and conflict resolution mechanism is implemented at the Group, commodity business, divisional, site and project levels that allows employees and contractors to directly or anonymously raise issues and make complaints with respect to SD performance and management, and that includes clear mechanisms for registering, evaluating and resolving all issues and complaints. SD Standard 12 Intent (Social & Community Engagement) - The social impact of our activities, community concerns, needs and the social risks to our operations are identified and addressed through the effective implementation of community relations strategies which uphold and promote human rights and respect cultural considerations and heritage. Social involvement plans aim to enhance the socio-economic capacity and well-being of the communities associated with the Group's activities, avoiding dependency and contributing to the development of sustainable livelihoods. Plans are established through engagement with communities and relevant organisations and are coordinated between the different levels of the organisation and with external governmental or development organisations. SD Standard 12.1 (Social & Community Engagement) - Community concerns and needs, as well the risks and impacts of site and project operations and activities on local communities, are identified and evaluated at each stage of the project life cycle or when any major modification to Xstrata's activities and operations occur or when significant changes occur in the communities. Where appropriate, this includes: · The systematic identification of external stakeholders · Human rights baseline studies and risk assessments that include security providers and activities · Social baseline studies and risk assessments SD Standard 12.2 (Social & Community Engagement) - We engage with all communities within the operation's area of influence and prioritise the most affected communities and vulnerable groups. SD Standard 12.3 (Social & Community Engagement) - Respect for the rights of local communities is demonstrated through an understanding of: · Traditional rights and cultural heritage, including those of indigenous peoples · Sensitivities involved in addressing issues of social impact, including avoiding the resettlement of people wherever possible · Local laws and customs

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Enduring Value Principle/Element · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Handling matters in a spirit of trust Upholding human rights, in particular with regard to the use of security providers and personnel in high-risk areas

SD Standard 12.4 (Social & Community Engagement) - Identified community concerns, needs, opportunities, and the risks and impacts of site and project operations and activities are prioritised ­ in close consultation with the communities concerned - and addressed via community strategies and social involvement plans as an integral part of our risk management and business planning processes. Where appropriate, this includes: · Community mapping · Institutional analysis ­ the evaluation of the variety, strength, and linkages of institutions within and around the relevant community · Problem census ­ the identification of community concerns through direct consultation with a broad range of community groups · Opportunity ranking · Identification of goals and assumptions · Identification of key performance indicators and measures of success PRINCIPLE 4 ­ IMPLEMENT RISK MANAGEMENT STRATEGIES BASED ON VALID DATA AND SOUND SCIENCE Xstrata SD Policy · Element 4.1 Consult with Xstrata Business Principles interested and affected parties in SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different the identification, levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and assessment and implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: management of all significant social, · Consider and address current and anticipated SD risks, in particular: o business opportunities health, safety, o issues and trends at the global, regional and local levels environmental and o discrete and aggregated risks an d impacts of our activities, operations, and projects across the life cycle economic impacts · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate associated with our activities · Reflect consultation with relevant internal and external stakeholders · Are documented and communicated to all appropriate levels within the commodity businesses; and · Element 4.2 · Are reviewed for continued effectiveness and updated annually. Ensure regular review and updating SD Standard 4.3 (Communication & Engagement) - Xstrata management communicates, engages and consults with employees and external stakeholders in the of risk management development, implementation and review of SD requirements and in the identification and assessment of SD risks.

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Enduring Value Principle/Element systems · Element 4.3 Inform potentially affected parties of significant risks from mining, minerals and metals operations and of the measures that will be taken to manage the potential risks effectively · Element 4.4 Develop, maintain and test effective emergency response procedures in collaboration with potentially affected parties Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of Xstrata's: · SD objectives, strategies, plans, targets, requirements and any recent changes to these · SD performance, risks and other SD matters SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 6.2 (Catastrophic Hazards) - Catastrophic hazard registers and plans are developed for each operation and in consultation with communities and other relevant external stakeholders. SD Standard 6.4 (Catastrophic Hazards) - Internal and external communication processes are established and used to allow those directly exposed to the hazard and others who have a legitimate interest in the hazard, to: · Understand how the hazards were identified · Understand why particular actions are required · Receive communication and training as required SD Standard 10.6 (Environment, Biodiversity & Land Management) - Information acquired from 10.4 and 10.5 is used, in consultation with affected and concerned external stakeholders, for the development and implementation of biodiversity and landscape function management systems and programmes. SD Standard 12.2 (Social & Community Engagement) - We engage with all communities within the operation's area of influence and prioritise the most affected communities and vulnerable groups.

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Enduring Value Principle/Element Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

SD Standard 15.2 (Incident Management) - Xstrata plc Board and Group Executive Committee are informed of all critical and high potential HSEC incidents in a timely and accurate manner. SD Standard 15.3 (Incident Management) - Commodity business boards or executive teams are provided with the following for all critical and high potential HSEC incidents: · Notification of the incident · Management of the incident · Outcomes of the investigation · Completion of corrective actions SD Standard 17.2 (Emergencies, Rises & Business Continuity) - Site and project emergency response and business continuity plans are developed in consultation with external emergency agencies to mitigate the assessed HSEC impacts and restore the business. These plans are: · Documented with defined roles and responsibilities · Communicated throughout the site or project · Made accessible to everyone at site or at the project · Maintained and updated through periodic testing SD Standard 17.3 (Emergencies, Rises & Business Continuity) - All employees and non-employees are trained in the emergency response plan to understand: · Their roles and responsibilities · The use of emergency response resources SD Standard 17.4 (Emergencies, Rises & Business Continuity) - Resources required for the management of emergencies are allocated and their adequacy reviewed SD Standard 17.5 (Emergencies, Rises & Business Continuity) -Emergency response, crisis management and business continuity plan exercises are conducted: · At least annually and as scheduled · With involvement from external emergency agencies, as appropriate · To review the completeness and currency of the HSEC emergency and crisis scenarios considered in site and project planning

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Enduring Value Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Principle/Element PRINCIPLE 5 ­ SEEK CONTINUAL IMPROVEMENT OF OUR HEALTH AND SAFETY PERFORMANCE Xstrata SD Policy · Element 5.1 Implement a Xstrata Business Principles ­ management system focused on continual SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different improvement of all levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively aspects of operations to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: that could have a significant impact on · Consider and address current and anticipated SD risks, in particular: the health and safety o business opportunities o issues and trends at the global, regional and local levels of our own o discrete and aggregated risks an d impacts of our activities, operations, and projects across the life cycle employees, those of contractors and · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate communities where · Reflect consultation with relevant internal and external stakeholders we operate. · Are documented and communicated to all appropriate levels within the commodity businesses; and · Are reviewed for continued effectiveness and updated annually. · Element 5.2 Take all practical and SD Standard 1. 6 (Leadership, Strategy & Accountability) - For all managers, employees and contractors the following arrangements are clearly defined, reasonable measures documented and communicated: to eliminate · Roles, responsibilities and accountabilities are allocated for specific SD risks and controls workplace fatalities, · Specific and measurable SD performance indicators injuries and diseases · SD organisational structures and lines of reporting among our employees and those SD Standard 3.1 (Behaviour, Awareness & Competency) - SD competency is achieved through: of our contractors. · Identifying the SD competencies required for all manager, employee and contractor positions and roles · The assessment of SD competency and awareness as a key selection criteria · Element 5.3 · Applicable induction processes that address Xstrata's Business Principles, Sustainable Development Policy and Sustainable Development Standards and specific Provide all SD requirements employees with · The establishment and maintenance of specific SD training plans for all positions and roles, including training in SD management systems health and safety · The identification and provision of appropriate competency-based SD training for all positions and roles training and require · The ongoing assessment of SD competence and the provision of SD refresher training as required employees of

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Enduring Value Principle/Element contractors to have undergone such training · Element 5.4 Implement regular health surveillance and risk-based monitoring of employees · Element 5.5 Rehabilitate and reintegrate employees into operations following illness or injury, where feasible. Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles The application of these requirements is appropriate to the SD obligations and the SD hazards associated with the work activities. SD Standard 3.3 (Behaviour, Awareness and Competency) Each operation implements a behavioural safety management programme.

SD Standard 5.1 (Risk & Change Management) - The Group risk management process and culture is used to drive continual improvement in SD performance through: · The development, implementation and continual improvement of systematic SD risk management processes and procedures · Systematic identification of SD hazards and external issues associated with Xstrata's operations · The assessment of SD risks, including those that aggregate at the Group, commodity business and division level, using recognised analysis and evaluation methodologies · Recording of SD risks in defined registers which are reviewed at least annually · Treatment of risks using options that are consistent with a `hierarchy of controls' and that is based on recognised analysis and evaluation methodologies · Periodic assurance of the adequacy and effectiveness of controls · Communication of information to potentially affected parties and other relevant parties on identified risks and controls and why particular treatment actions are required · The development and implementation of SD incident recovery plans SD Standard 6.1 (Catastrophic Hazards) - Hazards associated with facilities, structures, activities or situations are identified and assessed using systematic and rigorous processes that are implemented by suitably competent and experienced persons, including external experts if appropriate, to determine the individual hazards or combinations of hazards that could give rise to a sudden catastrophic event. SD Standard 6.6 (Catastrophic Hazards) - Management, in particular executive management, in each commodity business maintains and supports a catastrophic hazard management culture by: · Endorsing the catastrophic hazard management requirements · Maintaining knowledge and awareness of catastrophic hazards · Monitoring the status of nominated control measures · Reviewing and responding to recommendations and actions emanating from assurance activities · Committing the organisation to the ongoing task of better anticipating, understanding and, where reasonably practicable, eliminating or controlling catastrophic hazards. SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure health, safety, environment and community (HSEC)

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Enduring Value Principle/Element Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, other external requirements and changes to these, into the SD management system SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility · Adequate financial resources to ensure the integrity of critical plant, equipment and structures. · Sourcing specialist advice and support as required · Employee and contractor involvement · Hazard identification through hazard analysis, assessment and prioritisation · Identification and recording of all critical plant, equipment, structures and processes · Documented operating and safe work procedures · Permit to work systems · Competent operations and maintenance employees and contractors · Availability of appropriate operational safety information · Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems · Inspection and testing prior to commissioning new or re-introduced plant and equipment. · Documenting design parameters of plant and equipment · Monitoring and reviewing design parameters as applicable · Plant and equipment operators working within design parameters · Timely availability, quality and suitability of consumables and replacement parts · Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment SD Standard 8.2 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is confirmed by:

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Enduring Value Principle/Element · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Reviewing the effectiveness of inspection, testing and maintenance activities and procedures Reviewing the effectiveness of failure and incident analysis and the associated corrective actions Periodic operational integrity audits

SD Standard 9.1 (Health & Occupational Hygiene) - Occupational health assessment and surveillance systems and plans are established and implemented that include: · Pre-employment health assessments that establish a baseline position and assess fitness for work · Regular health surveillance appropriate to the level of exposure · Communication of the results of health assessments and surveillance with due regard for confidentiality SD Standard 9.2 (Health & Occupational Hygiene) - Occupational health and hygiene systems, plans, programmes and controls are established and implemented to: · Identify occupational health and hygiene hazards including those associated with all work environments and activities · Assess employee and contractor exposure to the hazards with reference to internationally recognised monitoring standards · Eliminate as far as reasonably practicable, or otherwise minimise exposure to, hazards · Provide personal protective equipment where other controls do not effectively reduce the risks · Drive continuous improvements in occupational health and hygiene SD Standard 9.3 (Health & Occupational Hygiene) - An effective illness and injury management system is implemented that: · Considers the location and nature of the operation, site or project and its ability to provide effective medical and first aid services · Considers the physiological, psychological and sociological elements of injury or illness · Ensures healthcare is administered under the guidance of properly qualified professionals · Ensures rehabilitation systems and procedures promote early intervention to assist optimum recovery from work-related injuries or illnesses and aid return to work · Takes all reasonably practicable steps to assist or provide rehabilitation and suitable duties to employees who are injured at work · Maintains the injured person's position for as long as is reasonably practicable or as specified under relevant laws SD Standard 9.4 (Health & Occupational Hygiene) - Systems exist to identify significant public health risks and to assess the potential or actual impact on Xstrata's employees, contractors and local communities associated with the operation, such as HIV and AIDS, tuberculosis and malaria. Where high or rapidly growing prevalence of HIV and AIDS is identified as a risk, confidential, voluntary HIV and AIDS counselling, testing and treatment programmes are implemented in the workplace, complemented by education and awareness-raising programmes. Initiatives to provide community access to testing and treatment for HIV and AIDS are undertaken where relevant, in partnership with appropriate stakeholders.

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Enduring Value Principle/Element Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

SD Standard 9.5 (Health & Occupational Hygiene) -The health and well-being of the workforce shall be promoted through access to health information and programmes SD Standard 17.1 (Emergencies, Crises & Business Continuity) - Foreseeable site and project HSEC emergencies and business HSEC crises are systematically identified and their HSEC impacts assessed, including those associated with activities adjacent to sites and projects PRINCIPLE 6 ­ SEEK CONTINUAL IMPROVEMENT OF OUR ENVIRONMENTAL PERFORMANCE Xstrata SD Policy · Element 6.1 Assess the positive, Xstrata Business Principles negative and indirect and the cumulative SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different impacts of new levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively projects ­ from to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies and Sustainable Development Standards and are developed and implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: exploration through closure · Consider and address current and anticipated SD risks, in particular: o business opportunities o issues and trends at the global, regional and local levels · Element 6.2 o discrete and aggregated risks an d impacts of our activities, operations, and projects across the life cycle Implement an · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate environmental management system · Reflect consultation with relevant internal and external stakeholders focused on continual · Are documented and communicated to all appropriate levels within the commodity businesses; and improvement to · Are reviewed for continued effectiveness and updated annually. review, prevent, mitigate or SD Standard 2.1 (Planning and Resources) - Annual SD plans are developed and implemented at the Group, commodity business, divisional, site and project levels in ameliorate adverse consultation with employees and other relevant internal and external stakeholders. SD plans: environmental · Align with Group, commodity business, divisional, site and project level SD strategies impacts · Address SD risks and performance issues at the planning, design, operational and closure phases · Allocate sufficient human and financial resources to achieve the planned SD activities including the use of specialist advice when needed · Element 6.3 · Clearly define the associated roles, responsibilities and accountabilities Rehabilitate land · Set specific schedules and deadlines

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Enduring Value Principle/Element disturbed or occupied by operations in accordance with appropriate postmining land uses · Element 6.4 Provide for safe storage and disposal of residual wastes and process residues · Element 6.5 Design and plan all operations so that adequate resources are available to meet the closure requirements of all operations Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles · Set realistic but challenging and measurable targets and performance indicators that are consistent across the Group, commodity business, divisional, site and project levels

SD Standard 2.4 (Planning and Resources) - SD programmes are developed and implemented at the appropriate level of the organisation when additional resources and focus are needed to address a specific SD performance issue or risk. SD Standard 10.1 (Environment, Biodiversity & Land Functions) - Systems and procedures are established and implemented to: · Identify and document all aspects of site and project operations and activities that impact, or could potentially impact, the natural environment including air, surface and groundwater, land, habitats, biodiversity and landscape functions (e.g. watershed management, control of soil erosion, and the creation of microclimates). · Conduct environmental baseline surveys and environmental impact assessments at appropriate points in the project or operating life cycle · Assess the aspects and identify significant and potential impacts that require priority attention and management and establish plans, programmes and targets as appropriate · Routinely review and update identified aspects when there have been significant changes or new developments to site and project operations and activities SD Standard 10.4 (Environment, Biodiversity & Land Functions) - Baseline biodiversity and landscape function studies are conducted at the feasibility or exploration phase of projects, or as soon as practicable for acquired operations without an appropriate baseline study, to: · Establish existing conditions of biodiversity and landscape function (e.g. watershed management, control of soil erosion, and microclimate creation) · Identify the potential impacts of proposed activities and operations that create risks to biodiversity and landscape functions · Identify relevant standards to be applied or used as benchmarks · Identify opportunities for improvements SD Standard 10.5 (Environment, Biodiversity & Land Functions) - Environmental risk assessments associated with impacts on biodiversity and landscape functions are undertaken for new operations or major changes to existing operations. SD Standard 10.7 (Environment, Biodiversity & Land Functions) - During the life cycle of a project including post-closure, the status of biodiversity shall be monitored and reviewed in terms of: · Species and habitat loss or gains · Factors that impact on biodiversity · Security of protected areas · Management of biological resources · Ongoing rehabilitation and restoration of ecosystems

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Enduring Value Principle/Element · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Resilience of the ecosystem

SD Standard 10.8 (Environment, Biodiversity & Land Functions) - Appropriate education and awareness about the environment, biodiversity and landscape function is provided to relevant personnel using specialist advice as required. SD Standard 10.9 (Environment, Biodiversity & Land Functions) - The environment, biodiversity and landscape function are addressed when determining postclosure land use and the conservation, rehabilitation or restoration of ecosystems as appropriate. SD Standard 10.10 (Environment, Biodiversity & Land Functions) - Scientific information on the best available current practices, including technologies, to protect and enhance the environment, biodiversity, conservation and landscape function is shared with relevant internal and external stakeholders as appropriate. SD Standard 13.1 (Life Cycle Management ­ Projects & Operations) - SD risks of new developments are identified, analysed, evaluated and treated by processes that include: · An appropriate level of baseline SD assessments prior to commencing exploration or construction activities · Pre-feasibility studies that identify any fundamental SD impediments, the completion of sufficiently detailed and robust social, health and environmental impact assessments and land-use assessments to determine the associated risks to be treated should the project proceed · The development and implementation of appropriate SD risk management strategies that meet Xstrata, commodity business, statutory and stakeholder requirements · A mechanism to ensure the transfer of knowledge concerning SD risks and their management, between each phase of the project life cycle · A phase by phase process designed and implemented to ensure that as new SD and operational information and knowledge is acquired, it is used to review and test the assumptions made at earlier phases of the project life cycle. · A mechanism to ensure, when appropriate, the transfer of knowledge concerning SD risks and their management, to other projects being implemented by Xstrata · The identification, assessment and management of property rights that considers: land tenure, cultural heritage, authority to access, and the level of community support SD Standard 13.2 (Life Cycle Management ­ Projects & Operations) - A documented project management system, relevant to SD issues, is used to deliver all projects and developments through: · Formal evaluation(s) of the conceptual design against defined SD criteria, prior to management approval · Formal evaluation(s) of the detailed design against defined SD criteria, prior to procurement or construction · Identification of all reasonably foreseeable SD risks, constraints and opportunities relating to the project, and the effective management of these · Compliance with Xstrata's Business Principles, Policies and Sustainable Development Standards and all relevant SD legislation, standards, codes and

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Enduring Value Principle/Element · · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles requirements Applying experience from previous projects and current operations in the appropriate context to project development Site and project management systems to manage construction SD risks Design and construction that complies with sound engineering and technical standards Periodic project audits that monitor project SD milestones and outcomes Design, construction and operation that considers closure planning SD requirements A commissioning plan that addresses operability requirements and employee competency

SD Standard 14.2 (Product Stewardship) -All relevant employees, contractors, customers and other relevant internal and external stakeholders are appropriately informed of the SD hazards associated with the handling, transport, use, storage and disposal of Xstrata's products. SD Standard 14.3 (Product Stewardship) -Strategies are implemented that support research and innovation aimed at improving the safe use and recycling of our products and developing technologies for extracting and processing metals and minerals that are efficient in the use of energy, natural resources and materials. PRINCIPLE 7 ­ CONTRIBUTE TO CONSERVATION OF BIODIVERSITY AND INTEGRATE APPROACHES TO LAND USE PLANNINED Xstrata SD Policy · Element 7.1 Respect legally Xstrata Business Principles designated protected areas SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of Xstrata's: · Element 7.2 · SD objectives, strategies, plans, targets, requirements and any recent changes to these Disseminate · SD performance, risks and other SD matters scientific data on and An independently verified Group Sustainability Report that meets international reporting standards is published annually and is supplemented by sustainability promote practices reports at a commodity business, division, site or project level as appropriate. Each report communicates with identified stakeholder groups. and experiences in biodiversity SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and assessment and non-governmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. management · Element 7.3 Support the development and SD Standard 10.1 (Environment, Biodiversity & Land Functions) - Systems and procedures are established and implemented to: · Identify and document all aspects of site and project operations and activities that impact, or could potentially impact, the natural environment including air, surface and groundwater, land, habitats, biodiversity and landscape functions (e.g. watershed management, control of soil erosion, and the creation of

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Enduring Value Principle/Element implementation of scientifically sound, inclusive and transparent procedures for integrated approaches to land use planning, biodiversity conservation and mining Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles · · · microclimates). Conduct environmental baseline surveys and environmental impact assessments at appropriate points in the project or operating life cycle Assess the aspects and identify significant and potential impacts that require priority attention and management and establish plans, programmes and targets as appropriate Routinely review and update identified aspects when there have been significant changes or new developments to site and project operations and activities

SD Standard 10.4 (Environment, Biodiversity & Land Functions) - Baseline biodiversity and landscape function studies are conducted at the feasibility or exploration phase of projects, or as soon as practicable for acquired operations without an appropriate baseline study, to: · Establish existing conditions of biodiversity and landscape function (e.g. watershed management, control of soil erosion, and microclimate creation) · Identify the potential impacts of proposed activities and operations that create risks to biodiversity and landscape functions · Identify relevant standards to be applied or used as benchmarks · Identify opportunities for improvements SD Standard 10.5 (Environment, Biodiversity & Land Functions) - Environmental risk assessments associated with impacts on biodiversity and landscape functions are undertaken for new operations or major changes to existing operations. SD Standard 10.8 (Environment, Biodiversity & Land Functions) - Appropriate education and awareness about the environment, biodiversity and landscape function is provided to relevant personnel using specialist advice as required. SD Standard 10.9 (Environment, Biodiversity & Land Functions) - The environment, biodiversity and landscape function are addressed when determining postclosure land use and the conservation, rehabilitation or restoration of ecosystems as appropriate. SD Standard 10.10 (Environment, Biodiversity & Land Functions) - Scientific information on the best available current practices, including technologies, to protect and enhance the environment, biodiversity, conservation and landscape function is shared with relevant internal and external stakeholders as appropriate.

PRINCIPLE 8 ­ FACILITATE AND ENCOURAGE RESPONSIBLE PRODUCT DESIGN, USE, RE-USE, RECYCLING AND DISPOSAL OF OUR PRODUCTS Xstrata SD Policy · Element 8.1 Advance Xstrata Business Principles understanding of the properties of metals SD Standard 4.4 (Communication & Engagement) - Relevant SD experience and knowledge is shared across Xstrata sites and with appropriate external and minerals and stakeholders, including evolving health, safety, environmental and community development knowledge regarding Xstrata's operations, activities and products. their life cycle effects

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Enduring Value Principle/Element on human health and the environment · Element 8.2 Conduct or support research and innovation that promotes the use of products and technologies that are safe and efficient in their use of energy, natural resources and other materials · Element 8.3 Develop and promote the concept of integrated materials management throughout the metals and minerals value chain · Element 8.4 Provide regulators and other stakeholders with scientifically sound data and analysis regarding our Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and non-governmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. SD Standard 7.1 (Legal Compliance & Document Control) - Systems and procedures are implemented to ensure HSEC legal compliance through: · Identification of all HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Tracking and identification of changes to all relevant HSEC legislation, standards, codes and additional external requirements to which the organisation subscribes that are applicable to Xstrata's operations · Creation and maintenance of a register of applicable HSEC legal documents and other documents pertaining to external requirements that are communicated and made accessible to employees · Communication to employees and contractors of new and amended legislation and other external requirements that would affect their accountabilities · Assessment of new or changed legislation or other external requirements to Xstrata's operations and business · Incorporation of applicable HSEC legal requirements, and other external requirements and changes to these, into the SD management system SD Standard 8.1 (Operational Integrity) - Operational integrity of plant, equipment, structures, processes and protective systems is achieved through the development and implementation of integrated management systems that address the following aspects: · Accountability and responsibility · Adequate financial resources to ensure the integrity of critical plant, equipment and structures. · Sourcing specialist advice and support as required · Employee and contractor involvement · Hazard identification through hazard analysis, assessment and prioritisation · Identification and recording of all critical plant, equipment, structures and processes · Documented operating and safe work procedures · Permit to work systems · Competent operations and maintenance employees and contractors · Availability of appropriate operational safety information · Maintenance, inspection, testing and calibration, including their associated instrumentation and control systems · Inspection and testing prior to commissioning new or re-introduced plant and equipment. · Documenting design parameters of plant and equipment · Monitoring and reviewing design parameters as applicable · Plant and equipment operators working within design parameters

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Enduring Value Principle/Element products and operations as a basis for regulator decisions · Element 8.5 Support the development of scientifically sound policies, regulations, product standards and material choice decisions that encourage the safe use of mineral products Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles · · Timely availability, quality and suitability of consumables and replacement parts Managing change through the identification and elimination/minimisation of hazards in new designs, modifications and updates to plant and equipment

SD Standard 10.10 (Environment, Biodiversity & Land Functions) - Scientific information on the best available current practices, including technologies, to protect and enhance the environment, biodiversity, conservation and landscape function is shared with relevant internal and external stakeholders as appropriate. SD Standard 11.1 (Contractors, Suppliers & Partners) - Contractors, suppliers and partners shall be selected based on defined sustainable development (SD) criteria which include: · A risk and performance based evaluation of their products and/or services · An evaluation of their past performance SD Standard 14.1 (Product Stewardship) - Systems, processes and procedures exist to: · Assess existing and new products and services for their SD benefits, impacts and risks over their life cycle · Identify opportunities to conduct or support research and innovation that leads to the development of products and technologies that have lower SD impacts and risks SD Standard 14.2 (Product Stewardship) - All relevant employees, contractors, customers and other relevant internal and external stakeholders are appropriately informed of the SD hazards associated with the handling, transport, use, storage and disposal of Xstrata's products. SD Standard 14.3 (Product Stewardship) - Strategies are implemented that support research and innovation aimed at improving the safe use and recycling of our products and developing technologies for extracting and processing metals and minerals that are efficient in the use of energy, natural resources and materials. SD Standard 16.1 (Monitoring & Review) - Processes are established and implemented so that SD performance is routinely measured, monitored, recorded, assessed and acted upon by management. This includes SD inspections and audits conducted by commodity businesses and sites at frequencies appropriate to their SD risks and performance. SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources:

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Enduring Value Principle/Element · · · · · · · Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments Health, safety, environment and community incident reports and investigation findings Performance data, trends, and reports including the extent to which targets and objectives have been met Inputs and views of external stakeholders, including complaints Status of corrective and preventative actions Outcomes from previous management reviews Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments

The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up. PRINCIPAL 9 ­ CONTRIBUTE TO THE SOCIAL, ECONOMIC AND INSTITUTIONAL DEVELOPMENT OF THE COMMUKNITIES IN WHICH WE OPERATE Xstrata SD Policy · Element 9.1 Engage at the Xstrata Business Principles earliest practical stage with likely SD Standard 1.3 (Leadership, Strategy & Accountability) - Xstrata management develops and implements well-founded and effective SD strategies at different affected parties to levels of the organisation that reflect Xstrata's SD objectives, values and commitments, address key SD performance issues and external factors and contribute positively discuss and respond to the SD goals. Long-term SD strategies are aligned to Xstrata's Business Principles, Policies, and Sustainable Development Standards and are developed and implemented at Group, commodity business, divisional, site and project levels. Specifically, SD strategies: to issues and conflicts concerning · Consider and address current and anticipated SD risks, in particular: the management of o business opportunities o issues and trends at the global, regional and local levels social impacts o discrete and aggregated risks an d impacts of our activities, operations, and projects across the life cycle · Address opportunities to have a positive impact on the quality of life, well-being and the SD of the communities in which we operate · Element 9.2 Ensure that · Reflect consultation with relevant internal and external stakeholders appropriate systems · Are documented and communicated to all appropriate levels within the commodity businesses; and are in place for · Are reviewed for continued effectiveness and updated annually. ongoing interaction with affected SD Standard 4.2 (Communication & Engagement) - Equitable and culturally appropriate processes are implemented and maintained to engage external stakeholders parties, making sure in respect of their SD concerns and expectations with regard to Xstrata's operations, activities and products that minorities and other marginalised SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of

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Enduring Value Principle/Element groups have equitable and culturally appropriate means of engagement · Element 9.3 Contribute to community development through closure in collaboration with host communities and their representatives · Element 9.4 Encourage partnerships with governments and non-government organisations to ensure that programmes (such as community health, education, local business development) are well designed and effectively delivered. · Element 9.5 Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles Xstrata's: · SD objectives, strategies, plans, target, requirements and any recent changes to these · SD performance, risks and other SD matters An independently verified Group Sustainability Report that meets international reporting standards is published annually and is supplemented by sustainability reports at a commodity business, division, site or project level as appropriate. Each report communicates with identified stakeholder groups. SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and non-governmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. SD Standard 4.8 (Communication & Engagement) - An external stakeholder grievance and conflict resolution mechanism is implemented at the Group, commodity business, divisional, site and project levels that allows external stakeholders to directly or anonymously raise issues and make complaints with respect to SD performance and management, and that includes clear mechanisms for registering, evaluating and resolving all issues and complaints. SD Standard 12.1 (Social & Community Engagement) - Community concerns and needs, as well the risks and impacts of site and project operations and activities on local communities, are identified and evaluated at each stage of the project life cycle or when any major modification to Xstrata's activities and operations occur or when significant changes occur in the communities. Where appropriate, this includes: · The systematic identification of external stakeholders · Human rights baseline studies and risk assessments that include security providers and activities · Social baseline studies and risk assessments SD Standard 12.2 (Social & Community Engagement) - We engage with all communities within the operation's area of influence and prioritise the most affected communities and vulnerable groups. SD Standard 12.3 (Social & Community Engagement) - Respect for the rights of local communities is demonstrated through an understanding of: · Traditional rights and cultural heritage, including those of indigenous peoples · Sensitivities involved in addressing issues of social impact, including avoiding the resettlement of people wherever possible · Local laws and customs · Handling matters in a spirit of trust · Upholding human rights, in particular with regard to the use of security providers and personnel in high-risk areas SD Standard 12.4 (Social & Community Engagement) - Identified community concerns, needs, opportunities, and the risks and impacts of site and project

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Enduring Value Principle/Element Enhance social and economic development by seeking opportunities to address poverty Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles operations and activities are prioritised ­ in close consultation with the communities concerned - and addressed via community strategies and social involvement plans as an integral part of our risk management and business planning processes. Where appropriate, this includes: · Community mapping · Institutional analysis ­ the evaluation of the variety, strength, and linkages of institutions within and around the relevant community · Problem census ­ the identification of community concerns through direct consultation with a broad range of community groups · Opportunity ranking · Identification of goals and assumptions · Identification of key performance indicators and measures of success SD Standard 12.5 (Social & Community Engagement) - Our community strategies and social involvement plans focus on enhancing the socio-economic capacity, prosperity and sustainable development of the local communities in which we operate in a manner that avoids dependency on the Xstrata site/operation after closure. Where appropriate, this includes: · Development and use of appropriate skills and technologies · Support for community educational initiatives and health programmes · Providing employment opportunities for local people · Sourcing and purchasing from local companies · Support for community projects · Promoting local enterprise development SD Standard 12.6 (Social & Community Engagement) - Commodity businesses formalise the budgeting and business planning process for prioritising and allocating commodity business social involvement funding in a manner that is coordinated with site and project level social involvement plans. SD Standard 12.9 (Social & Community Engagement) - Mutually understood and accepted community consultation mechanisms exist at commodity business, divisional, site, and project levels. A system is maintained to record community engagement activities and any complaints or inquiries from community members or other external parties together with Xstrata's response to these. SD Standard 12.10 (Social & Community Engagement) - Systems exist to measure and report on cash and in-kind contributions made towards community development by a commodity business, division, site or project.

PRINCIPLE 10 ­ IMPLEMENT EFFECTIVE AND TRANSPARENT ENGAGEMENT, COMMUNICATION AND INDEPENDENTLY VERIFIED REPORTING ARRANGEMENT WITH OUR

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SECTION 4: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO ENDURING VALUE (2004)

Enduring Value Principle/Element STAKEHOLDERS Element 10.1 Report on our economic, social and environmental performance and contribution to sustainable development Element 10.2 Provide information that is timely, accurate and relevant Element 10.3 Engage with and respond to stakeholders through open consultation processes Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles

Xstrata SD Policy Xstrata Business Principles SD Standard 4.2 (Communication & Engagement) - Equitable and culturally appropriate processes are implemented and maintained to engage external stakeholders in respect of their SD concerns and expectations with regard to Xstrata's operations, activities and products SD Standard 4.5 (Communication & Engagement) - Effective channels of communication exist to inform all employees and relevant external stakeholders of Xstrata's: · SD objectives, strategies, plans, targets, requirements, and any recent changes to these · SD performance, risks and other SD matters An independently verified Group Sustainability Report that meets international reporting standards is published annually and is supplemented by sustainability reports at a commodity business, division, site or project level as appropriate. Each report communicates with identified stakeholder groups. SD Standard 4.6 (Communication & Engagement) - Xstrata communicates and engages with relevant organisations such as governments, authorities, inter- and non-governmental organisations and national and international mining industry associations as appropriate to contribute to the development of SD knowledge, leading practice, public policy, legislation and other initiatives. SD Standard 4.8 (Communication & Engagement) - An external stakeholder grievance and conflict resolution mechanism is implemented at the Group, commodity business, divisional, site and project levels that allows external stakeholders to directly or anonymously raise issues and make complaints with respect to SD performance and management, and that includes clear mechanisms for registering, evaluating and resolving all issues and complaints. SD Standard 12.10 (Social & Community Engagement) - Systems exist to measure and report on cash and in-kind contributions made towards community development by a commodity business, division, site or project. SD Standard 16.1 (Monitoring & Review) - Processes are established and implemented so that SD performance is routinely measured, monitored, recorded, assessed and acted upon by management. This includes SD inspections and audits conducted by commodity businesses and sites at frequencies appropriate to their SD risks and performance. SD Standard 16.2 (Monitoring & Review) - Commodity businesses, sites and projects comply with Group and commodity business sustainable development assurance programmes. Non-conformances are addressed and the implementation and adequacy of corrective actions are tracked and assessed.

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SECTION 4: MAPPING OF XSTRATA SUSTAINABLE DEVELOPMENT POLICY & STANDARDS & BUSINESS PRINCIPLES TO ENDURING VALUE (2004)

Enduring Value Principle/Element Relevant Xstrata Sustainable Development Policy, SD Standard or Business Principles SD Standard 16.3 (Monitoring & Review) - Annual management reviews occur at all levels of the organisation to determine the continued suitability, adequacy and effectiveness of SD strategies, plans, systems, programmes and processes. This includes identifying and understanding the basis for good SD performance, and assessing the effectiveness with which it has been shared and acted upon across the organisation. Inputs to the management reviews shall typically include information from the following sources: · Internal and external SD inspections, assessments and audit reports addressing: operational, specialist, functional, management system, legal compliance and stakeholder requirements; or other external commitments · Health, safety, environment and community incident reports and investigation findings · Performance data, trends, and reports including the extent to which targets and objectives have been met · Inputs and views of external stakeholders, including complaints · Status of corrective and preventative actions · Outcomes from previous management reviews · Government policies and regulation, socio-economic or political developments and new scientific findings and technological developments The annual SD management reviews are documented and include observations, conclusions, recommendations and follow-up.

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