Sasol today announced that as part of its ongoing legal compliance programme, Sasol Limited's Chief Executive, Pat Davies, and his management team initiated a competition law compliance review of all Sasol businesses in July 2008. The competition law compliance review proactively analyses business activities across Sasol Limited and its subsidiaries.

 
"Over the past seven months, our existing compliance programmes have been further intensified, with this competition law compliance review. The review is comprehensive and rigorous but last year we gave an assurance to our shareholders, our customers and our employees that we will root out impropriety and we will not rest until we are confident that all our businesses are fully compliant," Davies said.
 
In addition to this compliance review, the Sasol Limited Board of Directors, on recommendation of management, commissioned a review of the adequacy of competition law compliance processes managed and co-ordinated across the Sasol Group. Sasol has retained external counsel to assist in this regard.
 
"The Board is fully appraised of the competition compliance review and fully supports the activities undertaken. The additional review, commissioned by the Board on the recommendation of management, takes a further look at the broader competition law compliance processes and the management and coordination thereof. External counsel will assist in this board-commissioned review and I feel this both a comprehensive and necessary set of activities," said Sasol Chairman, Hixonia Nyasulu
 
Sasol will, in the course of conducting the competition law compliance reviews, adopt appropriate remedial steps and make disclosures on the material findings as and when it is appropriate. It is currently envisaged that the review process will be completed during the first half of 2009.
 
At this stage, Sasol is in a position to disclose findings of the competition review process in respect of Sasol Nitro, Sasol Gas and Sasol Oil.
 
Sasol Nitro
 
Additional information has been revealed by the review process which is relevant to previously disclosed competition law legal proceedings in respect of the Nutri-Flo complaints and Phosphoric Acid investigation (See page 179 and 180 of the 2008 Annual Financial Statements and page F-75 and F-77 of the 2008 Annual Report on Form 20-F to the United States Securities and Exchange Commission for the previous public disclosures in these matters). On the basis of available information and legal advice available at the time of previous disclosures of these matters it was indicated that a finding of unlawful conduct under the Competition Act of South Africa in each of these matters was remote. Additional information uncovered in the review process and an ongoing assessment of the merits of these matters now indicate that a finding of unlawful conduct under the Competition Act is more probable in the Phosphoric Acid investigation and in respect of one of the complaints in the Nutri-Flo matter referred by the Competition Commission to the Competition Tribunal. Sasol has commenced exploratory discussions with the Competition Commission. It is premature to determine the possible consequences and financial impact of any finding of unlawful conduct at this stage.
 
Sasol Gas
 
The competition law compliance review referred to above, has also revealed two competition law contraventions in Sasol Gas. The first contravention relates to the structure of a piped gas marketing BEE joint venture which Sasol established and in which Sasol has a 49% interest. In support of the BEE joint venture Sasol agreed to certain restrictive provisions in the agreements relating to the venture. In addition Sasol provided marketing and administrative related services and assistance to this venture. These agreements were based on legal advice obtained at the time as well as an assumption that the venture could be treated as a partner rather than a competitor of Sasol Gas. Closer scrutiny and additional legal advice obtained as part of the competition law compliance review indicated that the assumption was not valid and that the assistance and services provided to the venture constituted a contravention of the South African Competition Act.
 
The second contravention relates to a restrictive clause in a supply agreement with a customer for the benefit of the customer. Sasol agreed to the restrictive clause to support the privatisation of the customer. Sasol is only to a limited extent a potential competitor of this customer.
 
Each of these contraventions was brought to the attention of the Competition Commission once they were identified. Sasol is co-operating with the Competition Commission and has been granted conditional corporate leniency by the Competition Commission in both these matters. We do not believe that these contraventions by Sasol Gas will have a material adverse impact on our business, operating results and financial condition.
 
Sasol Oil
 
Following a competition law compliance review, Sasol Oil was advised by its competition law advisors that certain identified conduct may be seen to be a contravention of certain provisions of the South African Competition Act.
 
Upon the identification of the potential concerns, Sasol Oil submitted leniency applications to the Competition Commission.
 
Competition Commission Announcement
 
The Competition Commission today announced that it has initiated investigations into the South African piped gas and petroleum industries as a result of Sasol's leniency applications. Sasol is co-operating fully with the commission in these investigations.
 
Davies said: "While we have always had compliance programmes in place, they do not erect an absolute barrier against behaviour that may be contrary to our policies or applicable laws or regulations. The intense scrutiny of the review initiated last year is unfortunately indicating areas of concern. We will not tolerate non-compliance and won't rest until we are confident that all our businesses are fully compliant not least because any contravention of law could potentially lead to fines, remedial actions and civil claims and therefore have a negative impact on Sasol's business and reputation. Where we do identify irregularities, we take a conservative approach and take prompt action to rectify the situation." he said.
 
Davies added: "Most importantly, our values do not leave any room for unethical behaviour. This detailed scrutiny of potential compliance issues is particularly necessary given the increasing complexity of both the business and legislative environments in which we operate and we will continue to intensify our compliance reviews accordingly."
 
Ends.