Sasol Form 20-F for the year ended 30 June 2021 - Book - Page 26
protection of the environment which may also affect
our operating results and financial condition. The
essential objectives of these legal frameworks are
largely consistent with that of the South African
framework, although regulatory and permitting
requirements are more established and entrenched in
some regions.
considering synergies with GHG reduction efforts in
the interest of implementing an overall environmentally
sustainable solution considering Sasol’s ambition to
decarbonise our operations. Introducing incremental
amounts of additional gas would allow us to accelerate
our GHG reduction plans while also enabling the
shutdown of boilers, thereby reducing the total mass of
Sasol’s SO2 emissions. It, however, remains likely that
the implementation of the selected solution will also
extend beyond 1 April 2025.
Competition laws/Anti-trust laws
Non-compliance with competition/anti-trust
legislation could expose the group to administrative
penalties, civil claims and damages, including punitive
damages by companies which can prove they were
harmed by the breach of competition/anti-trust
legislation. Such penalties and damages could be
significant and have an adverse impact on Sasol’s
business, operating results, cash flows and financial
condition. In addition, Sasol’s reputation could be
damaged by findings of such contraventions and
individuals could be subject to imprisonment or fines in
countries where competition/anti-trust violations are a
criminal offence.
Accordingly, we continue to assess available
legal mechanisms to leverage in mitigation of any
potential non-compliance risks that may arise on 1
April 2025, pending the completion of the air quality
roadmaps along adjusted timelines. We continue to
engage with the Department of Forestry, Fisheries and
the Environment (DFFE) and the local licensing
authorities as necessary. The outcome of these
processes and applications cannot be guaranteed and
may be successfully challenged by third parties and
hence the risk of non-compliance could still materialise.
Non-compliance may result in the violation of licence
conditions with the associated consequence of
administrative enforcement action, which may include
directions to cease operations and fines and penalties
including criminal prosecution. This may have a
material adverse impact on our business.
It is Sasol’s policy to comply with all laws.
Notwithstanding this, and our training and compliance
programmes, we could inadvertently contravene
competition/anti-trust laws and be subject to the
imposition of fines, criminal sanctions and/or civil
claims and damages. We endeavour to remain
compliant with competition/anti-trust legislation in all
the jurisdictions in which we operate to avoid any
material adverse impact on our reputation, business,
operating results, cash flows and financial condition.
We recognise that existing standards may
become stricter over time which may pose a risk to
some of our maturing operations in South Africa. This
may, in some cases, adversely affect our business,
financial condition, results of operations and cash
flows.
Data privacy laws and regulations
Some of our South African operations are
situated in declared air quality priority areas which are
subject to the requirements of the Vaal Triangle AirShed Priority Area Air Quality Management Plan and
the Highveld Priority Area Air Quality Management
Plan. These plans are currently under review, subject to
the completion of source apportionment studies, and are
also the subject of litigation currently. Accordingly,
further emission reduction commitments may be
required from Sasol and are likely to trigger additional
costs for air quality improvements in these priority
areas.
We operate in countries that have data
protection laws and regulations. It is our policy to
comply with all applicable laws, and we implement
numerous training, awareness and data privacy
compliance programmes. However, non-compliance
with data protection laws could result in fines and/or
civil claims and damages. This could have a material
adverse impact on our reputation and a consequential
financial impact.
South African mining legislation may have an
adverse effect on our mineral rights
Outside of South Africa, we operate a number
of plants and facilities for the storage and processing of
chemical feedstock, products and wastes. These
operations are subject to numerous laws, regulations
and ordinances relating to safety, health and the
In December 2019, the Minister of Mineral
Resources and Energy (Minister) separated oil and gasrelated matters from that of mineral related matters in
the Mineral and Petroleum Resource Development
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