Business Context and Reporting Period
Company: Gold Fields Limited
Filing Type: Form 6-K (Report of Foreign Private Issuer)
Date: February 12, 2020
Subject: Disclosure of a material weakness in internal control over financial reporting (ICFR) and ineffective disclosure controls and procedures as of December 31, 2018.
Key Financial Metrics
The filing text does not provide specific values for revenue, profit, cash flow, margins, debt, or liquidity. The document focuses exclusively on the identification and remediation of internal control deficiencies rather than reporting operational financial results.
Material Changes and Control Deficiencies
- Material Weakness Identified: A deficiency in recording transactions between the "cost close" date and the calendar year-end in the statement of cash flows.
- Root Cause: Inadequate evaluation of risks regarding transactions occurring in the normal course of business between the cost close date (December 21, 2018, and December 22, 2017) and December 31.
- Impact on Controls: Management concluded that ICFR and disclosure controls were ineffective as of December 31, 2018.
- Remediation Status: Deficiencies were remediated as of December 31, 2019, with new controls designed to identify and account for material transactions between cost close and year-end.
Correction of Errors and Outlook
- Error Classification: The control deficiencies resulted in adjustments to financial statement captions (balance sheet and cash flows). Management assessed these adjustments under SAB No. 99 and SAB No. 108 and concluded they were immaterial to previously issued financial statements taken as a whole.
- Financial Statement Impact: No adjustments were made to the consolidated income statement, statement of changes in equity, or statement of comprehensive income. Affected line items for prior periods were revised, with unaffected items grouped as "other."
- Reliance on Prior Reports: The Company's 2018 ICFR report and KPMG Inc.'s attestation report can no longer be relied upon.
- Future Reporting: The Company plans to include its updated ICFR assessment as of December 31, 2019, in its upcoming Form 20-F filing for the fiscal year ended December 31, 2019.
Investor Verification Checklist
- Verify the unaudited results for the year ended December 31, 2019, attached as Exhibit 99.1 to the Form 6-K for specific financial impacts.
- Monitor the upcoming Form 20-F filing for the formal assessment of ICFR effectiveness as of December 31, 2019.
- Confirm that no restatements of previously filed annual reports are required, as the errors were deemed immaterial under SAB No. 99.
- Review the specific nature of the "cost close" vs. "calendar year-end" gap to understand the scope of the control failure.