Independent assurance statement

To the board and stakeholders of Blue Label Telecoms:

SustainabilityAssurance.co.za (SA) was commissioned by Blue Label Telecoms (hereafter, BLT) to provide independent third-party assurance over the 2009 sustainability report (the report, covering the period 1 June 2008 to 31 May 2009) contained within BLT ’s integrated annual report. The assurance team comprised primarily of Michael H Rea, our principal corporate social responsibility (CSR) consultant, with experience in environmental and social performance measurement. Over the past 10 years, Michael has undertaken over 30 assurance engagements in various countries, including Sudan, Kenya, the DRC, Nigeria, Cameroon, Swaziland, Zimbabwe, Namibia, South Africa, Peru and Canada: working either as part of a team (while in the employ of PWC and KPMG), or as an Independent CSR consultant.

Independence

SA was not responsible for the preparation of any part of this report and has not undertaken any commissions for BLT in the reporting period concerning reporting or data collection. SA’s responsibility in performing its assurance activities is to the management of BLT alone and in accordance with the terms of reference agreed with them.

Assurance objectives

The objectives of the assurance process were to provide stakeholders of BLT with a low level independent assurance opinion on whether the report meets standard reporting principles of completeness, accuracy, consistency and neutrality, as well as to assess the degree to which the report is consistent with the Global Reporting Initiative (GRI) G3 guidelines, with the objective of establishing whether or not the report has met the Global Reporting Initiative (GRI) G3 Application Level C reporting requirements.

Scope of work performed

The process used in arriving at this assurance statement is based on best practices in sustainability reporting assurance. Our approach to assurance included the following:

• Reviews of drafts of the report for significant data and/or assertion anomalies, and to assess whether sufficient ‘neutrality’ (ie success and challenges) could be identified.
• Interviews with individuals responsible for writing the report in order to assess BLT ’s measurement and reporting procedures, and to ensure that selected claims/assertions could be substantiated.
• A review of the process used to define the content of the report by looking at materiality of issues included in the report, determination of sustainability context and coverage of material issues.
• A review of the approach of management to addressing topics discussed in the report.
• An assessment of whether or not the requisite number of GRI G3 performance indicators have been covered in the report to meet Application Level C requirements.

Findings

In general, the company’s sustainability reporting processes are adequate, and this report reflects a significant improvement over BLT ’s 2008 report.

However, it was found that:

• Although BLT actively engages an array of key stakeholders, as defined within this report, the assurance process did not allow for additional engagement to confirm or refute BLT ’s assertion that the report adequately reflects the information requirements of their key stakeholders.
• Although additional performance data would be required to enhance the overall quality of BLT ’s sustainability reports, this report appears to reflect an accurate accounting of BLT ’s sustainability performance for the period ending 31 May 2009.

Based on our review of the report, as well as the processes employed to collect and collate information reported herein, it is our assertion that this report meets the GRI G3’s requirements for Application Level C (responses to all required indicators, as well as no fewer than 10 core indicators, with at least one from each of social, economic and environment). However, it was found that:

• The reporting of performance against some GRI G3 indicators continues to require either data quality improvements, or further detail in disclosure, particularly with respect to environmental performance. Indicator-specific performance is identified in BLT ’s GRI G3 indicator table.

Recommendations

While we are satisfied that this report is a fair demonstration of BLT ’s ability to collect, collate and report on its sustainability performance, the following recommendations have been identified:

• BLT should ensure that stakeholder engagement procedures include an assessment of whether or not this report, and all future reports, adequately reflect the reporting requirements of key stakeholders.
• BLT should continue to improve its reporting according to international best practice, including the principles of inclusiveness, materiality, and responsiveness, as guided by AA 1000AS (2008), ultimately seeking an AA1000AS form of assurance in future reports.
• Having addressed the requirements of GRI G3 Application Level C, it is our recommendation that BLT review the process followed in compiling the report and, while making further improvements on the quality of data required for Application Level C, begin addressing the requirements of Application Level B.

Conclusions

Based on the information reviewed, and citing BLT ’s status as a recently listed company (second year of JSE Limited listing), SustainabilityAssurance.co.za is satisfied that this report provides a reasonably comprehensive and balanced account of the environmental, safety and social performance of BLT during the period under review. The data presented is based on policies and procedures that are, in many cases, still in the process of further development and/or implementation, and we are satisfied that the reported performance data reasonably represents the current environmental, safety and social performance of BLT . Moreover, and although the quality or quantity of data of many GRI G3 indicators can yet be improved, this report appears to meet the GRI G3’s requirements for Application Level C (C+ with this assurance engagement).

SustainabilityAssurance.co.za
22 October 2009