ARTIMUS
Harmony Gold Mining Group — RMA Portfolio
R2.1B PORTFOLIO
269 REPUDIATIONS
Historical Portfolio
R2.1B
All years, all mines
Total Claims (11 Yrs)
16,371
2015–2026 across 14 entities
Group Repudiations
269
All products and years
NIHL Repudiations
175
65% of all repudiations
Section 40 Flagged
35
Employer reporting failures
Product Gaps
4
CJP, Funeral, GLA, DIP missing

Mine Entities

Tap a mine to expand
Universal Products (All 14 Mines)
COID · AUG · CICJP · PRMA
Core cover across entire portfolio
Products No Mine Has
GLA · DIP · CJP
Critical coverage gaps group-wide
Funeral Cover
1 / 14
Only Corporate HO (003H) has funeral benefit — 13 mines unprotected
Mines With All 4 Gaps
13 / 14
No CJP, no Funeral, no GLA, no DIP

Full Coverage Matrix

CodeMineCOIDAUGCICJPCJPFuneralGLADIPPRMA

COID=Compensation for Occupational Injuries & Diseases · AUG=Accidental Under-Group · CICJP=Combined IOD Claims Journey Policy · CJP=Commuting Journey Policy · GLA=Group Life Assurance · DIP=Disability/Income Protection · PRMA=Platinum Rand Mutual Assurance

Total Repudiations
269
2015–2026 across all products
NIHL (PLH < 10%)
175
65.1% of all repudiations — top driver
CJP Doc Failures
17
14-day submission rule violation — preventable
Section 40 Flagged
35
Employer reporting failures
Fatal Claim Rep.
6
Families potentially unpaid
Paid Before Rep.
R424K
Medical costs on later-repudiated claims

Repudiations by Mine

CodeMineCOIDAUGCICJPCJPTotalNIHLPaid on Rep.
NIHL Repudiations
175
65% of all repudiations
Total NIHL Claims
1,705
2015–2026 full portfolio
Total NIHL Paid
R117M
All accepted NIHL claims
Avg NIHL Value
R68,649
Per accepted NIHL claim
Recovery Potential
~R2.4M
Conservative 20% appeal success rate

Primary Repudiation Grounds

1
PLH Deterioration < 10% From Valid Baseline
The dominant NIHL repudiation ground. Under Instruction 171 of COIDA, the employee's Percentage Loss of Hearing must deteriorate by at least 10% from the valid baseline audiogram. The majority of NIHL repudiations fail on this threshold — often by a small margin. Proactive audiometric monitoring can identify at-risk workers before claims are lodged.
2
No Causal Connection to Occupational Noise
The hearing deterioration observed is inconsistent with NIHL and cannot be attributed to workplace noise exposure levels. Requires independent audiological assessment to challenge. Consider specialist review for borderline cases.
3
Noise Exposure Below 85dB Threshold
Based on current noise exposure levels, the employee has not been exposed to excessive noise equivalent to 85 dB for 8 hours/day, 5 days/week — the COIDA minimum threshold. Workplace noise mapping should be reviewed and updated regularly.
4
Conductive Component Exclusion
When the conductive hearing loss component (not caused by occupational noise) is disregarded, the PLH does not reach the 10% threshold. A technical argument that may be contestable with specialist audiological input and case-by-case review.

NIHL Repudiations by Mine

Fatal Claim Repudiations
6
Families potentially left unpaid across 5 mines
CJP Repudiations
17
ALL due to doc non-submission within 14 days — 100% preventable
Mines Without Funeral
13 / 14
Only 003H Corporate HO has funeral benefit
Worst CJP Mine
043P
9 CJP repudiations at Moab Khotsong alone

Fatal Pension Repudiations

MineCodeFatal Rep.Notes
Target (Avgold)020B2Dependants' pension status unclear — immediate follow-up required
Moab Khotsong043P1Fatal pension repudiated
Masimong105E1Dependant status to confirm
Chemwes106D1Dependant status to confirm
Joel Mine016D1Dependant status to confirm

CJP Repudiations by Mine

MineCodeCJP Rep.Cause (All Same)
Moab Khotsong043P9Acceptance form + Road Accident Questionnaire not submitted within 14 days (Clause 15.2.1)
Freegold016C3Same as above
Randfontein 032A032A1Same as above
Randfontein 105B105B1Same as above
Tshepong016E1Same as above
Target020B1Same as above
HGM Ltd105A1Same as above
Root Cause: 100% Correctable Process Failure
All 17 CJP repudiations share one root cause — failure to submit the CJP Policy Acceptance of Benefits Form and Road Accident Questionnaire within 14 days of the incident (Clause 15.2.1). This is entirely preventable through a dedicated CJP submission checklist and mine-level documentation training. Zero cost intervention, high recovery value.
Funeral/GLA Monthly Opp.
R30M+
Across 13 unprotected mines
DIP Monthly Opp.
R29M+
Across portfolio
CJP Monthly Opp.
R3.7M+
Across portfolio
NIHL Recovery
~R2.4M
20% conservative appeal success

Opportunity by Mine

CodeMineCOID LivesFuneral/GLA (p/m)DIP (p/m)CJP (p/m)

ⓘ Figures sourced from the 2025 Opportunity Sizing model based on COID lives per mine and actuarial per-worker contribution rates. Subject to underwriting review before client presentation.

Priority Action Plan

1
FUNERAL COVER — Immediate Rollout (13 Mines)
The single most critical gap. 13 of 14 Harmony entities have zero funeral benefit. In a deep underground gold mining environment, this leaves dependants entirely reliant on COIDA fatal pension claims — which face repudiation risk and processing delays. Monthly opportunity exceeds R30M across the portfolio. Escalate immediately to all mine principals.
2
CJP DOCUMENTATION TRAINING — Priority: 043P, 016C
17 CJP repudiations are entirely attributable to one correctable process failure: non-submission within 14 days. Implement dedicated CJP documentation process at all mines, priority at Moab Khotsong (9 repudiations) and Freegold (3). Zero cost intervention with direct recovery value.
3
NIHL AUDIOMETRIC MONITORING PROGRAMME
175 NIHL repudiations represent a systemic, unmet welfare need. Recommended: (a) proactive audiometric monitoring to track PLH trend before claims are lodged; (b) clear employee communication on COIDA thresholds; (c) supplementary AUG hearing protection cover for workers approaching threshold. Recovery potential: ~R2.4M at conservative 20% appeal success.
4
GLA & DISABILITY/INCOME PROTECTION — Strategic Rollout
No mine carries GLA or DIP. Given the high rate of serious injuries — head (2,517 claims, R226M), knee/lower leg (1,429 claims, R212M), wrist/hand (2,061 claims, R199M) — these products provide income continuity for permanently disabled workers and financial security for dependants. Combined monthly DIP opportunity: R29M+.
5
SECTION 40 COMPLIANCE — Group-Wide Training
35 repudiated claims carry Section 40 flags, indicating systemic employer reporting failures under COIDA. Implement structured Section 40 compliance training group-wide, with focus on Moab Khotsong, Tshepong, and Golden Core — the three highest-volume repudiation mines.

Top Injury Categories — Group Total 2015–2025

CategoryTotal ClaimsTotal PaidAvg/ClaimFlag
Injuries to the Head2,517R226MR89,869PD% often challenged on audit
Injuries Wrist & Hand2,061R199MR96,643High disability lump-sums likely under-assessed
Noise Induced Hearing Loss1,705R117MR68,649175 repudiated — ~R2.4M appeal potential
Injuries Ankle & Foot1,447R83MR57,394Declining volumes, high per-claim value
Injuries Knee & Lower Leg1,429R212MR148,544Ongoing PD pensions — very high action risk
Current Disability Spend
R114.3M
Per reporting period — TTD + PD pensions + PD lump sums
43.4% of ALL claims spend
Annual IOD Claim Rate
4.53%
16,371 claims ÷ 11 years ÷ 32,871 COID lives
≈ 299 disability cases per year
Disability Incidence Rate
0.91%
Per covered worker per year (conservative)
20% of IOD claims result in disability
DIP Group Monthly Opportunity
R26.7M
Actuarial per-worker rates across 13 mines
R319.8M annually — converts risk to fixed cost
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WHY SHOULD THE MINE TAKE OUT DIP COVER?
The direct financial impact on the employer — not just the worker
What the mine pays today (uninsured)
1
Mandatory 3-Month TTD Advance
Employer pays 75% of capped earnings for first 3 months — recoverable via WCL6 only if filed correctly. Across Harmony: R50.9M TTD spend — WCL6 recovery completeness unaudited.
2
The COIDA Earnings Cap Gap
COIDA caps at R54,153/month. Worker earning R65,000 gets only R40,615 (75% of cap). Gap = R8,135/month per above-cap disabled worker. Mine absorbs this informally or faces union dispute.
3
Replacement Cost per Permanent Disability
Recruitment + induction + underground competency certification = ~R85,000 per permanently disabled worker who cannot return. Underground gold: high replacement friction.
What DIP eliminates for the mine
✓ WCL6 Gap Eliminated
Where WCL6 not filed, DIP ensures worker is covered — removes the mine's informal obligation to top up
✓ COIDA Cap Gap Covered
DIP pays the gap directly to the worker. Mine has zero informal liability for above-cap earnings during disability
✓ COIDA Dispute Buffer
Where a COIDA claim is repudiated, DIP continues paying — worker doesn't come back to the mine
✓ Section 40 Risk Reduction
Demonstrable care for disabled workers reduces additional compensation exposure under Section 40 employer negligence claims
The CFO Argument: Known Cost vs Unknown Exposure
DIP converts open-ended, informal, unpredictable disability liability into a defined, fixed monthly premium. The mine stops absorbing R8,135/month informal gaps, unrecovered WCL6 advances, and replacement costs — and replaces them with a single line item on the income statement.
R114.3M
Current disability spend (recorded)
+
 
Unknown
Informal top-ups & unrecovered WCL6
=
 
Fixed
DIP premium replaces all of this
A
ACTUARIAL ASSUMPTIONS
All inputs used in the employer risk calculation — fully auditable
COIDA Earnings Cap (monthly, 2024)
R54,153
R649,836 p.a. — Gov. Gazette Notice R.1028, effective 1 March 2024
COIDA TTD Benefit Rate
75%
Statutory: 75% of capped monthly earnings paid during temporary total disablement
Employer TTD Advance Period
3 months
Employer pays first 3 months before RMA takes over. Recoverable via WCL6
Annual IOD Claim Rate
4.53%
Derived: 16,371 claims ÷ 11 years ÷ 32,871 COID lives (Harmony DRG data)
IOD Claims Resulting in Disability
20%
Conservative industry rate for deep-level gold mining (TTD >90 days + PD combined)
Disability Claim Rate (per worker)
0.91%
Derived: 4.53% × 20% — approx. 299 disability cases per year across group
Workers Earning Above COIDA Cap
30%
Conservative: senior miners, team leaders, artisans, engineers in deep-level gold
Avg. Above-Cap Earnings (monthly)
R65,000
Conservative for team leaders and artisans. Actual earnings often higher
Income Gap Per Disabled Worker (p/m)
R8,135
(R65,000 − R54,153) × 75% TTD rate — per above-cap worker, per month
Assumed Disability Duration
6 months
Conservative minimum. PD cases run for life — this model shows minimum exposure only
Replacement Cost (permanent disability)
R85,000
Recruitment + induction + underground competency certification per replaced worker
% of Disability Cases Assumed Permanent
20%
Conservative permanent disability rate in deep-level gold mining
ƒ
HOW WE CALCULATE EMPLOYER RISK
Three-component formula — applied per mine, per year
For each mine, the uninsured employer exposure is the sum of three components. All figures are conservative minimums — actual exposure for PD cases running for life is materially higher.
A
Employer TTD Advance = Annual disability claims × R54,153 × 75% × 3 months
The mandatory employer cash advance during the first 3 months of disability. Recoverable via WCL6 — but only if filed. Unrecovered advances are a permanent cash loss.
B
Income Gap = Annual disability claims × 30% above-cap × R8,135/month × 6 months
For every above-cap worker disabled, COIDA pays only on R54,153. The mine informally absorbs the gap or faces union pressure. DIP eliminates this completely.
C
Replacement Cost = Annual disability claims × 20% permanent × R85,000
Permanently disabled workers must be replaced. Underground gold replacement: advertising, agency fees, medical fitness, induction, and competency certification.
=
Total Employer Risk = A + B + C (per mine, per year)
This is the uninsured, open-ended exposure the mine carries today. DIP converts it to a fixed monthly premium.
$
PER-MINE DISABILITY RISK vs DIP PREMIUM
What each mine is exposed to vs what DIP would cost them monthly
CodeMineCOID Lives Ann. Disability
Claims
Dis. Rate Employer Risk
(A+B+C Annual)
DIP Premium
(Monthly)
DIP Annual
Cost

ⓘ Employer risk figures are conservative minimums. PD cases running for life multiply component B significantly. DIP premium from 2025 Opportunity Sizing model.

GROUP NET POSITION — THE SAVINGS CASE
What disability is already costing Harmony vs what DIP costs to fix it
Disability Spend — Current Period
R114.3M
TTD R50.9M + PD Pensions R29.7M + PD Lump Sums R33.7M
43.4% of ALL claims spend
Unrecorded Informal Exposure
Unknown
WCL6 gaps + cap-gap top-ups + union settlements
Not in any report — absorbed silently by mines
DIP: Annual Group Premium
R319.8M
R26.7M/month × 12 — covers all of the above
Fixed cost. No surprises.
Disability Spend as % of Total Claims Spend
Medical CostsR90.5M — 34.3%
Fatal PensionsR57.3M — 21.8%
TTD (Employer Advance)R50.9M — 19.3%
PD Lump SumsR33.7M — 12.8%
PD Pensions (ongoing)R29.7M — 11.3%
Disability total (TTD + PD): R114.3M = 43.4% of all claims spend — the single largest cost category
The Key Point for the CFO Conversation
The DIP premium (R319.8M annually) appears larger than current recorded disability spend (R114.3M). This comparison is misleading in the mine's favour — because R114.3M is what RMA pays to workers. It does not include: informal top-ups for above-cap earners, unrecovered WCL6 advances where the form wasn't filed, HR and management time in disability disputes, union settlements, or replacement costs. DIP covers ALL of this — the recorded spend plus the hidden spend — for a single known monthly amount.
✓ What the Mine Gets for the DIP Premium
1. WCL6 recovery gap eliminated — zero cash loss if form not filed
2. COIDA earnings cap gap covered for all above-cap workers
3. Worker paid during COIDA repudiation — mine not in the dispute
4. Section 40 additional compensation risk reduced
5. Labour relations posture improved — tangible welfare commitment
6. Replacement cost pressure reduced — clean exit for permanent disability
DISABILITY RISK BY INJURY CATEGORY
Which injuries are driving the highest disability spend — and where DIP is most critical
The five highest-value injury categories from the 11-year DRG data. These are the workers most likely to generate long-term disability pensions — and the ones where the COIDA earnings cap gap is most expensive for the mine.
Injury Category Total Claims Total Paid Avg / Claim DIP Relevance
Knee & Lower Leg 1,429 R212M R148,544 Highest avg value — ongoing PD pensions likely. Most at risk of permanent disability above cap.
Head Injuries 2,517 R226M R89,869 High volume + high value. Cognitive impairment cases create long-term disability.
Wrist & Hand 2,061 R199M R96,643 Fine motor loss often prevents return to underground work — permanent replacement.
NIHL (Hearing Loss) 1,705 R117M R68,649 175 repudiated — workers with no COIDA payout. DIP covers them while repudiation appealed.
Ankle & Foot 1,447 R83M R57,394 Lower avg value but high volume. Declining trend — engineering controls improving.
▲ Heat / Radiation / Pressure 332 Surging TBC 100× growth since 2015 (0 → 332 in 2025). Emerging DIP risk — long-term disability potential unknown.