COMBINED ASSURANCE

Assurance process

FirstRand has commissioned the following independent sources to provide assurance and commentary on its 2009 Corporate Governance and Sustainability Statement:

• BEE transformation performance has been externally audited by SizweNtsaluba VSP;
• FirstRand’s carbon footprint data has been externally prepared by PricewaterhouseCoopers Inc; and
• Group Internal Audit performed a limited review of the statements and quantitative data contained in the Corporate Governance and Sustainability Statement.

Internal Audit Assurance statement

Based on the results of the work performed, FirstRand’s 2009 Corporate Governance and Sustainability Statement:

• provides confidence in the information presented within the report. The level of data accuracy was found to be within acceptable limits, but additional improvements were recommended to management to reduce potential for minor anomalies and misstatements;
• appropriately reflects environmental, social and economic performance achieved during the period;
• represents a fair statement of FirstRand’s corporate social responsibility initiatives; and
• contains quantitative data which is free from material misstatement.

Notwithstanding that the data collection process is sufficiently transparent, FirstRand shows continued improvement and refinement on its method of collecting data for the Corporate Governance and Sustainability Statement to ensure an even more accurate result. All suggested changes were satisfactorily addressed by FirstRand management prior to finalising the report.

Overall, the report is an appropriate representation of FirstRand’s corporate governance and sustainability performance during the reporting period, based on the limited material sampling approach applied to the assurance engagement.

J John
Chief audit executive
14 September 2009

NON FINANCIAL ACCOUNTING POLICIES

FirstRand’s non financial accounting policies are aligned to the Global Reporting Initiative’s (“GRI”) G3 guidelines, incorporating recommendations set out in the King Committee on Governance’s Code of Governance Principles for South Africa (2009) (King III Code), the JSE Socially Responsible Investment (“SRI”) index, and the BEE transformation requirements set out by the Financial Sector Charter, and the Department of Trade and Industry’s (“dti”) Codes of Good Practice.

Disclosures relating to non financial issues have been selected from those recommended in the GRI G3 Guidelines, the GRI Financial sector supplement, the JSE SRI index criteria, the FSC and dti criteria. The principles of materiality and stakeholder inclusiveness have been employed to ensure that non financial disclosures are material and relevant.

Material topics are defined as those reflecting significant economic, environmental and social impacts, or those that would influence the decisions of the company’s stakeholders. These topics are addressed in order of priority based on their materiality, and relevance to stakeholders.

Data measurement techniques are replicable, and information is not reported if the margin for error is believed to substantially influence the ability of stakeholders to make informed decisions about the company’s performance. Measurement techniques, estimates and underlying assumptions are described when it is materially necessary to do so.