SOCIAL PERFORMANCE POLICY SCOPE This policy is applicable to all the entities of De Beers. Members of De Beers may adapt the policy to include local legislative and stakeholder priorities within the countries in which they operate. RESPONSIBILITY FOR THE POLICY The maintenance, revision and distribution of this policy are the responsibility of the De Beers Group Head of Social Performance. SOCIAL PERFORMANCE POLICY De Beers is committed to taking responsibility for the short and long term economic, social and environmental implications of its decisions across the diamond pipeline. We commit to building diamond dreams through effective partnerships and enhancing the confidence of consumers in diamonds. In pursuit of the highest standards of social performance, De Beers is committed to: y Managing all aspects of this Social Performance Policy as an integral part of business. y Developing and implementing appropriate social performance policies, systems, programmes and training across all parts of our business. y Complying with relevant legislation in local jurisdictions where operating and other requirements to which De Beers subscribes, and aligning with international good practice. y Allocating resources commensurate to social risks, potential impacts and socio-economic opportunities to ensure the appropriate implementation of social management plans and the meeting of our commitments across all parts of our business. y Embedding social performance across the organisation through a culture of shared responsibility and accountability which integrates social performance considerations into business decision making. y Engaging in a transparent and inclusive manner with local stakeholders to improve understanding, promote constructive interaction and seek solutions to common social issues and challenges. y Delivering a lasting positive socio-economic benefit to our host countries and communities through leveraging our core business for development impact and engaging in additional corporate social investment activities. y Adopting the mitigation hierarchy approach by first assessing, seeking to avoid, minimising and then mitigating potential social impacts and risks when planning, designing and implementing exploration, mining and related activities. y Respecting human rights including the right of Indigenous Peoples to Free, Prior and Informed Consent. y Utilising a formal management approach to investigate, respond and, where appropriate, provide redress to social incidents and stakeholder grievances. y Ensuring that comprehensive social performance planning, costing and implementation for exploration, project, operational and closure phases is undertaken. y Recognising that potentially vulnerable groups within our affected communities could be disproportionately impacted by or less able to benefit from our activities due to the fact that they may be marginalised, historically disadvantaged and disempowered and seeking to redress this imbalance. y Complying with the requirements of the Social Way management system at all operating mines as the foundation for continuous improvement. y Managing potential risks to community health, safety and security including integrating stakeholders into emergency response planning, and implementing the Voluntary Principles on Security and Human Rights. y Avoiding resettlement where possible and following international best practice when either physical or economic displacement are unavoidable. y Seeking to avoid and, where avoidance is not possible, minimise and mitigate impacts on cultural heritage. y Including appropriate social performance requirements in our contractual agreements when significant potential adverse social impacts and/or opportunities to deliver socio-economic development exist. y Regularly monitoring and evaluating social performance to ensure compliance with this Policy and to facilitate continuous improvement. y Reporting social risks and performance publicly and providing assurance to the De Beers Société Anonyme Board of Directors through the Sustainability Committee. OBJECTIVE The objective of this policy is to provide requirements for the leadership, management, application and administration of social performance within The De Beers Group of Companies (De Beers). VERSION: JULY 2016 Bruce Cleaver, CEO, De Beers Group Gareth Mostyn, Executive Head of Strategy and Corporate Affairs