Sasol Form 20-F for the year ended 30 June 2021 - Book - Page 25
the possible impact they could have on our group’s
activities. These trade and economic sanctions are not
always aligned and this increases the complexities
when a company has operations in various countries. A
violation of any of these sanction regimes could lead to
a loss of import or export privileges, penalties against
or the prosecution of Sasol and our employees, which
could have an adverse effect on our reputation,
business, operating results, cash flows and financial
condition.
other regulatory authorities, which would require
additional financial and management resources.
Actual or alleged non-compliance with regulatory
requirements could result in criminal or civil
sanctions or could harm our reputation and
negatively impact our licence to operate
Non-compliance with anti-corruption and antibribery laws, sanction laws, environmental laws,
competition or anti-trust laws and data privacy laws
have been identified as our top five regulatory risks.
We have a sanctions compliance programme
and sanctions screening systems in place. We believe
that we are in compliance with all applicable sanctions
and other trade restrictions and intend to maintain such
compliance. However, there can be no assurance that
we will be in compliance in the future, particularly as
the scope of certain laws may be unclear and may be
subject to frequent amendments or changing
interpretations.
Anti-corruption and anti-bribery laws
Ethical misconduct and non-compliance with
applicable anti-corruption/anti-bribery laws could result
in criminal or civil sanctions and could have a material
adverse impact on our reputation, operations and
licence to operate.
Environmental laws and regulations
Companies need to be particularly vigilant
with regard to the risk of bribery, especially when the
scale of investments and the corruption perception of
the countries where operations take place are
considered. We, like other international petrochemical
companies, have a geographically diverse portfolio and
conduct operations in some countries which have a
perceived high prevalence of corruption. Our operations
must comply with applicable anti-bribery laws, such as
the US Foreign Corrupt Practices Act as well as similar
anti-corruption and anti-bribery laws of South Africa
and other applicable jurisdictions. There has been a
substantial increase in the global enforcement of these
laws. In particular, major investments in countries with
a high corruption exposure create an elevated risk when
dealing with private companies, governments or
government-controlled entities. We have an anticorruption and anti-bribery compliance programme in
place which is designed to prevent and reduce the
likelihood of violations of such laws by our employees
and companies associated with us. However, a violation
could result in substantial criminal or civil sanctions
and could damage our reputation.
In recent years, the environmental legislation
in South Africa has resulted in significantly stricter
standards. For instance, by 1 April 2020, our existing
plants were required to meet the more stringent point
source standards for air quality emissions applicable to
newly commissioned plants. Meeting some of these
requirements requires the retrofitting of some of our
existing plants, and accordingly, we obtained
postponements until 1 April 2025 from the National Air
Quality Officer to implement abatement projects in
accordance with our air quality roadmaps. Sasol’s
short-term cash conservation measures necessitated
capital deferment. This was implemented in 2020 with
associated project execution delays, which necessitates
the ongoing revision of our air quality roadmap
delivery as Sasol’s financial position improves.
Meeting the new boiler sulphur dioxide (SO2)
emission standards before 31 March 2025 remains a
challenge for our Secunda steam plant boiler
considering the time required to implement the possible
solutions. Coal beneficiation has the potential to
effectively reduce SO2 emissions to below 1000
mg/Nm3, the recently promulgated standard. However,
coal beneficiation is only likely beyond 1 April 2025
due to the magnitude and complexity of the
implementation which will entail an extensive scope
across mining and manufacturing plants. Coal
beneficiation is not, however, aligned to Sasol’s
sustainability objectives nor the long-term vision of
moving away from coal. In parallel with this, we are
Sanctions laws
Our international operations require
compliance with applicable trade and economic
sanctions or other restrictions imposed by governments,
such as the US and United Kingdom, and organisations,
such as the United Nations, the European Union (EU)
and its member countries. We closely monitor
developments in these sanction programmes and assess
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