Shangoni provides various compliance audit services which include HSE Legal Compliance Audits (LCAs) and compliance audits against the conditions of specific authorisations for example Environmental Authorisations, Environmental Management Programmes (EMPrs), Explosives Licences, Water Use Licences, Waste Management Licences.

HSE Legal Compliance Audits (LCAs) identify legal non-compliances and areas of high risk and are therefore an effective tool to avoid legal liability. The requirement to conduct LCAs on a regular basis is often included in environmental

permits and authorisations and in International Standards such as ISO and OHSAS that require periodic evaluations of compliance with applicable legal Requirements. When conducting an HSE LCA, Shangoni Legal Services incorporates HSE legal requirements into an audit framework that focus on the principles as specified in the National Environmental Management Act 107 of 1998 (NEMA) and the Occupational Health and Safety Act 85 of 1993 (OHSA) or the Mine Health and Safety Act 29 of 1996 (MHSA), as applicable. Compliance is evaluated against all national, provincial and local HSE legislation applicable to the client’s activities, products and services.


The process starts off with a desktop document review, during which important relevant documentation is evaluated.

A site visit is then conducted to evaluate implementation of all relevant HSE legislation.

We provide a detailed report indicating compliance, areas of concern, areas of non-compliance and recommendations for improvement.


In terms of regulation 34 of the 2014 EIA Regulations (GN R982 of 4 December 2014) holders of mining rights are required to appoint an external and independent auditor to undertake a compliance audit on the commitments in their EMPrs and the conditions of their environmental authorisations. Shangoni Legal Services together with our technical specialists assist clients with these compliance evaluations.

As the various authorisations do overlap and integrate with the LCA, Shangoni favours an integrated audit approach, thereby limiting the client’s time-requirements and minimising cost, whilst still providing separate reports in accordance with the relevant legislative requirements.


Corrie Potgieter



012 807 7036