INDEPENDENT ASSURANCE REPORT
TO THE DIRECTORS OF NEDBANK LIMITED

FOR THE YEAR ENDED 31 DECEMBER

SCOPE OF OUR ENGAGEMENTS

PART A
We have completed our independent reasonable assurance engagement to enable us to express our reasonable assurance conclusion on whether the following key performance indicators (‘specified KPIs’) contained in the Nedbank Group Limited Integrated Report’s Sustainable Development section (‘the Report’) for the year ended 31 December 2010 have been prepared, in all material respects, in accordance with the basis of preparation as described on page 5 as part of the section headed ‘Independent assessment and Global Reporting Initiative indices’ (‘management’s sustainability criteria’):

1 The total rand value of donations paid by Nedbank Group employees via deductions from their monthly salaries to the South African Children’s Charity Trust for the 12 months ended 31 December 2010 as disclosed in the table headed ‘Payroll Giving programme’ within the table row ‘2010 staff donations’ on page 124.

2 The total tonnes of paper used (purchased) by Nedbank Group for the 12 months ended
31 December 2010 as disclosed in the table headed ‘Nedbank South Africa performance targets’ under the ‘Paper’ section of the table within the table row ‘Tonnes used’ on page 110.

3 The total electricity consumed by the Nedbank campus sites in kilowatt hours for the 12 months ended 31 December 2010 as disclosed directly under the table headed ‘Nedbank South Africa performance targets’ and preceded by an asterisk on page 110.

4 The total water consumed by the Nedbank campus sites in kilolitres for the 12 months ended
31 December 2010 as disclosed on page 106 as part of the section headed ‘Water’.

5 The total number of incidents raised by Nedbank Group employees and handled by the Nedbank Group Internal Ombudsman for the 12 months ended 31 December 2010 as disclosed on page 138 as part of the section headed ‘Internal Ombudsman’.

6 The total rand value of unexpected medical costs paid to Nedbank Group employees from the Holsboer Benefit Fund for the 12 months ended 31 December 2010 as disclosed as part of bullet number four of the bulleted list on page 140.

7 The total electricity consumed by the Nedbank Retail branch sites in kilowatt hours for the 12 months ended 31 December 2010 as disclosed directly under the table headed ‘Nedbank South Africa
performance targets’ and preceded by an asterisk on page 110.

8 The total rand value of the donations made by Nedbank Group to The Green Trust, from a selection of qualifying Nedbank products, as a result of client use of these products for the 12 months ended
31 December 2010 as disclosed on page 113 as part of the section headed ‘Nedbank Green Affinity and The Green Trust’.

9 The total rand value of the donations made by Nedbank Group to the Nelson Mandela Children’s Fund, from a selection of qualifying Nedbank products, as a result of client use of these products for the 12 months ended 31 December 2010 as disclosed directly under the bulleted list in the section headed ‘Examples of NMCFsupported projects include’ on page 127.

10 The total rand value of the donations made by Nedbank Group to The Sports Trust, from a selection of qualifying Nedbank products, as a result of client use of these products for the 12 months ended
31 December 2010 as disclosed directly under the bulleted list in the section headed ‘The Nedbank Sport Affinity and The Sports Trust’ on page 127.

11 The total rand value of the donations made by Nedbank Group to the Arts & Culture Trust, from a selection of qualifying Nedbank products, as a result of client use of these products for the 12 months ended 31 December 2010 as disclosed directly under the bulleted list in the section headed ‘The Nedbank Arts Affinity and the Arts & Culture Trust’ on page 126.

12 The total rand value of corporate social investment spend by the Nedbank Foundation for the 12 months ended 31 December 2010 as disclosed directly above the graph headed ‘Nedbank Foundation CSI spend 2010 – by focus area’ and preceded by an asterisk on page 120.

13 The total rand value of payment requisitions loaded for payment to small and medium enterprises (SMEs) within seven days of Nedbank Group receiving the invoice from the SMEs for the 12 months ended 31 December 2010 as disclosed on page 133 as part of the section headed ‘Preferential procurement’.

14 The total rand value of training spend on black Nedbank Group employees (excluding contractors) for the 12 months ended 31 December 2010 as disclosed on page 143 as part of the section headed ‘Training spend’.

15 The total number of qualifying bursaries awarded to Nedbank Group employees from the External Bursaries Fund and managed by the National Student Financial Aid Scheme for the 12 months
ended 31 December 2010 as disclosed on page 143 as part of the section headed ‘Nedbank Bursary Scheme’.

16 The total rand value and total number of study grants provided to Nedbank Group employees from the Study Grant Fund for the 12 months ended 31 December 2010 as disclosed on page 143 as part of the section headed ‘Nedbank Bursary Scheme’.

17 The total rand value of internal bursaries awarded to Nedbank Group employees from the Internal Bursary Fund for the 12 months ended 31 December 2010 as disclosed on page 143 as part of the section headed ‘Nedbank Bursary Scheme’.

PART B
We have completed our independent limited assurance engagement to enable us to express our limited assurance conclusion on whether anything has come to our attention that causes us to believe that the following specified KPIs contained in the Report for the year ended 31 December 2010 have not been prepared, in all material respects, in accordance with management’s sustainability criteria as described on page 5 as part of the section headed ‘Independent assessment and Global Reporting Initiative indices’:

1 The total scope 1, 2 and 3 emissions of Nedbank Group in tonnes of carbon dioxide equivalent for the 12 months ended 31 December 2010 as disclosed in the table headed ‘Nedbank Group GHG emissions inventory’ within the table row ‘Total Nedbank Group emissions CO2e (tonnes)’ on page 109.

2 The total tonnes of paper collected for recycling from Nedbank campus sites for the 12 months ended 31 December 2010 as disclosed on page 106 as part of the section headed ‘Paper’.

3 The total water consumed by the Nedbank Retail branch sites in kilolitres for the 12 months ended 31 December 2010 as disclosed on page 106 as part of the section headed ‘Water’.

4 The total number of tipoffs received by Nedbank Group as a result of the Nedbank Tip-Off Anonymous initiative for the 12 months ended 31 December 2010 as disclosed on page 177 in the paragraph headed ‘Internal and external whistleblowing reporting lines’.

5 The total number of client complaints as recorded by the Nedbank Group Client Compliant Tracker System for the 12 months ended 31 December 2010 as disclosed in the table headed ‘Clients’ within the table row ‘Improve service levels to worldclass standards’ on page 14.

6 The total rand value of donations paid by Nedbank Group in accordance with its AskOnce Promise to Nedbank Group-designated charities for the 12 months ended 31 December 2010 as disclosed in the section headed ‘AskOnce Promise – drives service’ on page 77.

7 The total tonnes of general (domestic) waste collected from Nedbank campus sites to be disposed of in landfills for the 12 months ended 31 December 2010 as disclosed on page 107 as part of the section headed ‘Waste and recycling’.

8 The total number, category and value (in US dollars) of Nedbank Group deals that qualify under the Equator Principles and had their first drawdown for the 12 months ended 31 December 2010 as disclosed in the table headed ‘Total Equator deals 2007 – 2010’ on page 67 and the information indicated in bold green preceding the table.

PART C
We have completed our independent limited assurance engagement to enable us to express our limited assurance conclusion on whether anything has come to our attention that causes us to believe that the Report for the year ended 31 December 2010 has not been prepared, in all material respects, in accordance with the self-declared Global Reporting Initiative G3 Guidelines A+ application level using the principles of materiality, completeness and sustainability and in accordance with AccountAbility’s AA1000APS (2008) using the principles of inclusivity, materiality and responsiveness.

The specified KPIs noted in Part A and Part B have been emphasised for identification purposes in the Report in bold green.

Our responsibility in performing our independent reasonable and limited assurance engagements is to Nedbank Limited only and in accordance with the terms of reference for these engagements as agreed with it. To the fullest extent permitted by law we do not accept or assume responsibility to anyone other than Nedbank Limited for our work, for this report, or for the conclusions we have reached.

Nedbank Limited has elected to prepare:

  • The specified KPIs in accordance with management’s sustainability criteria, of which a full copy can be obtained as described on page 5 of the Report as part of the section headed ‘Independent assessment and Global Reporting Initiative indices’.
  • The Report in accordance with the principles of the G3 guidelines published by the Global Reporting Initiative, of which a full copy can be obtained from the Global Reporting Initiative website.
  • The Report in accordance with the principles of AA1000APS (2008) published by AccountAbility, of which a full copy can be obtained from the AccountAbility website.

 

DIRECTORS' RESPONSIBILITY

The directors are responsible for implementing a stakeholder engagement process to identify all relevant stakeholders, to identify key issues, to respond appropriately to key issues identified, to determine those key performance indicators that may be relevant and material to the identified stakeholders, and to design and apply appropriate sustainability reporting policies. The directors are also responsible for the preparation and presentation of the Report and the information and assessments contained in the Report in accordance with the relevant criteria. This responsibility includes designing, implementing and maintaining appropriate performance management and systems to record, monitor and improve the accuracy, completeness and reliability of the sustainability data, and to ensure that the information and data reported meet the requirements of the relevant criteria and contain all relevant disclosures that could materially affect any of the conclusions drawn.

ASSURANCE PROVIDER'S RESPONSIBILITY


Our responsibility is to express our assurance conclusions on the Report and the specified KPIs in accordance with the scope of our engagements, based on our independent reasonable and limited assurance engagements. Our independent assurance engagements were performed in accordance with the International Federation of Accountants’ International Standard on Assurance Engagements (ISAE) 3000 Assurance Engagements Other Than Audits or Reviews of Historical Financial Information. This standard requires us to comply with ethical requirements and to plan and perform our engagements to obtain the assurance required by the scope of our engagements, as expressed in this report.

BASIS OF WORK AND LIMITATIONS

The procedures selected depend on our judgement, including the assessment of the risks of material misstatement of the subject matter and the purpose of our engagement. In making these assessments we have considered internal control relevant to the entity’s preparation and presentation of the Report and the information contained therein in order to design procedures appropriate for gathering sufficient appropriate assurance evidence to determine that the information in the Report is not materially misstated or misleading, as set out in the summary of work performed below. Our assessment of relevant internal control is not for the purpose of expressing a conclusion on the effectiveness of the entity’s internal controls.

We planned and performed our work to obtain all the information and explanations that we considered necessary to provide a basis for our assurance conclusions pertaining to the Report and the specified KPIs, as expressed below.

Where a limited-assurance conclusion is expressed, our evidence-gathering procedures are more limited than for a reasonable assurance engagement, and therefore less assurance is obtained than in a reasonable-assurance engagement.

Our Report does not extend to providing assurance on historical data, unless specified in this Report.

SUMMARY OF WORK PERFORMED

Set out below is a summary of the procedures performed pertaining to the Report and the specified KPIs that were included in the scope of our assurance engagements:

          • We obtained an understanding of –
            − the entity and its environment;
            − entity-level controls;
            − the stakeholder dialogue process;
            − the selection and application of sustainability reporting policies;
            − how management has applied the principle of materiality in preparing the Report and the specified KPIs; and
            − the significant reporting processes, including how information is initiated, recorded, processed and reported and how incorrect information is corrected, as well as the policies and procedures within the reporting processes.
          • We made such enquiries from management, employees and those responsible for the preparation of the Report and the specified KPIs as we considered necessary.
          • We inspected relevant supporting documentation and obtained such external confirmations and management representations as we considered necessary for the purposes of our engagement.
          • We performed analytical procedures and limited tests of detail responsive to our risk assessment and the level of assurance required, including comparison of judgementally selected information to the underlying source documentation from which the information has been derived.

          Further to the above, below follows a summary of the procedures performed as part of our limited-assurance engagement as set out in Part C:

          • We considered whether Nedbank Limited has applied the Global Reporting Initiative G3 Guidelines to a level described on page 206.
          • We considered whether Nedbank L imited has applied the AA1000 principles of inclusivity, materiality and responsiveness.

          We believe that the evidence obtained as part of our assurance engagements is sufficient and appropriate to provide a basis for our findings and our assurance conclusions expressed below.

        BASIS FOR QUALIFIED OPINION

PART A
The company’s records reflect estimated electricity use and were not updated to reflect actual electricity use (specified KPI 7). The company’s records did not permit the application of alternative assurance procedures. Consequently we did not obtain sufficient appropriate assurance evidence regarding the accuracy and completeness of the specified KPI.

We were unable to obtain the supporting documentation considered necessary with respect to the accuracy and completeness of specified KPIs 8 – 11 and 18. Consequently we did not obtain sufficient appropriate assurance evidence regarding the accuracy and completeness of the specified KPIs.

BASIS FOR QUALIFIED CONCLUSION

PART B
The company’s records reflect estimated electricity use and were not updated to reflect actual electricity use (Part A, KPI 7). Electricity use is also a material component of the company’s green house gas calculation (specified KPI 1). The company’s records did not permit the application of alternative assurance procedures. Consequently we did not obtain sufficient appropriate assurance evidence regarding the accuracy and completeness of the specified KPI. The company’s records reflect estimated water use and were not updated to reflect actual water use (specified KPI 3).

The company’s records did not permit the application of alternative assurance procedures. Consequently we did not obtain sufficient appropriate assurance evidence regarding the accuracy and completeness of the specified KPI.

OPINION

PART A
Based on the work performed and subject to the limitations described above, except for the possible effects of the matters described above in the ‘Basis for qualified opinion’ paragraphs, in our opinion the
specified KPIs are prepared, in all material respects, in accordance with management’s sustainability criteria.

CONCLUSIONS

PART B
Based on the work performed and subject to the limitations described above, except for the possible effects of the matters described above in the ‘Basis for qualified conclusion’ paragraphs, nothing has come to our attention that causes us to believe that the specified KPIs have not been prepared, in all material respects, in accordance with management’s sustainability criteria.

PART C
Based on the work performed and subject to the limitations described above, nothing has come to our attention that causes us to believe that the Report has not been prepared, in all material respects, in accordance with the self-declared Global Reporting Initiative G3 Guidelines A+ application level using the principles of materiality, completeness and sustainability and in accordance with AccountAbility’s AA1000APS (2008) using the principles of inclusivity, materiality and responsiveness.

Ernst & Young Inc
Director – Jeremy Grist
Registered Auditor
Chartered Accountant (SA)
Wanderers Office Park
52 Corlett Drive
Illovo
Johannesburg
11 March 2011


BASIS OF MEASUREMENT FOR ASSURED KEY PERFORMANCE INDICATORS

Ernst & Young has been engaged to provide assurance on the key performance indicators as outlined in their assurance report ("specified KPIs") on pages 208 – 211 of the Nedbank Group Integrated Report 2010. The Nedbank Group has prepared the specified KPIs in accordance with the basis of measurement as indicated below.

Please e-mail Brigitte Burnett at BrigitteBu@Nedbank.co.za if you would like to find out more about the basis of measurement used for the specified KPIs.

All page references below are to the Nedbank Group Integrated Report 2010.

1. Payroll Giving Programme (Page number: 124)
- The total Rand value of donations paid by Nedbank Group employees via deductions from their monthly salaries to the South African Children’s Charities Trust (SACCT), for the twelve months ended 31 December 2010.

2. Paper Use (Page number: 110)
- The total tonnes of paper used (purchased) by the Nedbank Group, for the twelve months ended 31 December 2010.

3. Electricity Consumption (Campus sites) (Page number: 110)
- The total electricity consumed by the Nedbank Campus sites in kilowatt hours (kWh), for the twelve months ended 31 December 2010.

4. Water Consumption (Campus sites) (Page number: 106)
- The total water consumed by the Nedbank Campus sites in kilolitres (kl), for the twelve months ended 31 December 2010.

5. Internal Ombudsman (Page number: 138.)
- The total number of incidents raised by Nedbank Group employees and handled by the Nedbank Group Internal Ombudsman, for the twelve months ended 31 December 2010.

6. Holsboer Benefit Fund (Page number: 140)
- The total Rand value of unexpected medical costs paid to Nedbank Group employees from the Holsboer Benefit Fund, for the twelve months ended 31 December 2010.

7. Electricity Consumption (Retail) (Page number: 110)
- The total electricity consumed by the Nedbank Retail branch sites in kilowatt hours (kWh), for the twelve months ended 31 December 2010.

8. The Green Trust donations (Page number: 113)
- The total Rand value of the donations made by the Nedbank Group to the Green Trust from a selection of qualifying Nedbank products, as a result of client use of these products for the twelve months ended 31 December 2010. The value of the donations are determined in accordance with the rules applicable to the Green Trust as described in the “Nedbank Affinity Programme – How it works” induction document.

9. The NMCF donations (Page number: 127)
- The total Rand value of the donations made by the Nedbank Group to the Nelson Mandela Children’s Fund (NMCF) from a selection of qualifying Nedbank products, as a result of client use of these products for the twelve months ended 31 December 2010. The value of the donations are determined in accordance with the rules applicable to the NMCF as described in the “Nedbank Affinity Programme – How it works” induction document.

10. The Sports Trust donations (Page number: 127)
- The total Rand value of the donations made by the Nedbank Group to the Sports Trust from a selection of qualifying Nedbank products, as a result of client use of these products for the twelve months ended 31 December 2010. The value of the donations are determined in accordance with the rules applicable to the Sports Trust as described in the “Nedbank Affinity Programme – How it works” induction document.

11. The Arts and Culture Trust donations (Page number: 126)
- The total Rand value of the donations made by the Nedbank Group to the Arts and Culture Trust from a selection of qualifying Nedbank products, as a result of client use of these products for the twelve months ended 31 December 2010. The value of the donations are determined in accordance with the rules applicable to the Arts and Culture Trust as described in the “Nedbank Affinity Programme – How it works” induction document.

12. Nedbank Foundation Spend (Page number: 120)
- The total Rand value of Corporate Social Investment (CSI) spend by the Nedbank Foundation, for the twelve months ended 31 December 2010. The Rand value of CSI spend is determined in accordance with the definition for CSI spend developed by the Nedbank Group, as disclosed in the Corporate Social Investment – Nedbank Foundation section on pages 119-120 of the Nedbank Group Integrated Report 2010.

13. Early Payment of SMEs (Page number: 133)
- The total Rand value of payment requisitions loaded for payment to SMEs within seven days of the Nedbank Group receiving the invoice from the SMEs, for the twelve months ended 31 December 2010.

14. Training spend for Black staff (Page number: 143)
- The total Rand value of training spend on black Nedbank Group employees (excluding contractors) for the twelve months ended 31 December 2010. For the purposes of determining this Rand value, black Nedbank Group employees are defined as African, Indian and Coloured employees.

15. External Bursary Programme (Page number: 143)
- The total number of qualifying bursaries awarded to Nedbank Group employees from the External Bursaries Fund and managed by the National Student Financial Aid Scheme (NSFAS), for the twelve months ended 31 December 2010.

16. Study Grant Assistance (Page number: 143)
- The total Rand value and total number of study grants provided to Nedbank Group employees from the Study Grant Fund, for the twelve months ended 31 December 2010.

17. Internal Bursary Fund (Page number: 143)
- The total Rand value of internal bursaries awarded to Nedbank Group employees from the Internal Bursaries Fund, for the twelve months ended 31 December 2010.

18. GHG emissions (Page number: 109)
- The total scope 1, 2 and 3 emissions of the Nedbank Group in tonnes of carbon dioxide equivalent, for the twelve months ended 31 December 2010. The carbon footprint measurements are determined in accordance with the standard for Greenhouse Gas accounting and reporting (GHG Protocol).

19. Paper Recycled (Campus sites) (Page number: 106)
- The total tonnes of paper collected for recycling from the Nedbank Campus sites, for the twelve months ended 31 December 2010.

20. Water Consumption (Retail) (Page number: 106)
- The total water consumed by the Nedbank Retail branch sites in kilolitres (kl), for the twelve months ended 31 December 2010.

21. Tip-offs received (Page number: 177)
- The total number of tip-offs received by the Nedbank Group as a result of the Nedbank Tip-Off Anonymous initiative which is managed by Deloitte, for the twelve months ended 31 December 2010.

22. Client complaints via the client compliant tracker system (Page number: 14)
- The total number of client complaints as recorded by the Nedbank Group Client Compliant Tracker (CCT) system, for the twelve months ended 31 December 2010.

23. Ask once promise (Page number: 77)
- The total Rand value of donations paid by the Nedbank Group in accordance with its Ask Once Promise to a list of twelve Nedbank Group designated charities, for the twelve months ended 31 December 2010. In accordance with the Ask Once Initiative, the Nedbank Group undertakes to donate R50 per Ask Once Complaint logged, to a client-elected charity. Customers can report complaints where any one of the Nedbank Group’s seven promises for improved service delivery has been broken, by accessing the following link: http://www.nedbank.co.za/website/content/askonce/askonce.asp

24. General Waste sent to Landfills (Page number: 107)
- The total tonnes of general (domestic) waste collected from Nedbank Campus sites to be disposed of in landfills, for the twelve months ended 31 December 2010.

25. Equator Principles Project Finance (Page number: 67)
- The total number, category and value (in US Dollars) of Nedbank Group deals qualifying under the Equator Principles, and which had their first draw-down during the twelve months ended 31 December 2010.