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To, through the process of liaising, consulting and negotiating at the
appropriate levels with company management on issues of mutual concern, promote
safety, monitor and promote harmonious and productive working relationships
between members of the Association and the company. The person appointed to that
position pursuant to that agreement, was certain Mr Eddie Dye. Pursuant to
Nell's instruction to Smit to investigate existing structures in the technical
department and the extension thereof to the structures in the Human Resources
Department with Bloom, then acting as the relieving Human Resources Manager also
being involved in the exercise, Bloom proposed a new structure for the Human
Resources Department in which, inter alia, the position of hostel manager was
found to be redundant and surplus to the needs of the Respondent.

The situation in the technical department was reviewed and certain positions
therein were identified as being redundant, by Smit. These included the position
of Chief Engineer, at the time held by the Second Applicant, Sectional Engineer
in the metallurgical department, held by the Fourth Applicant, Ventilation
Engineer in the environmental department, held by the Sixth Applicant, Chief
Electrician, held by the Ninth Applicant, two Engineering Supervisor positions,
respectively held by the Fifth Applicant and certain Campbell and Engineering
Technical Assistant in the risk co-ordination department, held by the First
Applicant.

Two other positions, neither of them in either the technical or Human Resources
Departments, were also identified as being redundant and these were the position
of Raise-Bore supervisor, held by the Eighth Applicant and Acting Chief
Electrician at the Respondent's No 6 Shaft, held by the Seventh Applicant. I
have made earlier reference to the closure of the Raise-Bore department. It is
common cause that when that occurred the Eighth Applicant, Mr A G Waldeck,
applied for voluntary retrenchment and that his application was approved but
aborted in the face of an ongoing security investigation involving him.

On 30 December the gravamen of the analyses thus carried out and the positions
identified therefrom as redundant were communicated by Bloom to UASA in the
person of the association representative Dye. The individuals holding the 13
positions affected were all members of the Respondent's senior management and
Bloom testified that what was then agreed was that each individual would be
apprised of the overall state of affairs and his own resultant redundancy in a
separate interview, that alternative employment would be sought for him
elsewhere in the group and that in the event of vacancies thus being identified,
interviews would be set up and if no alternative employment resulted therefrom,
further discussions would be held regarding retrenchment packages.

This process was to take place during the first week of January and the
association representative if he wished or was so required, "would be welcome to
attend interviews or seek clarity on behalf of members. Separate meetings were
then held by Bloom with the Third and Seventh Applicants in which they were
informed that their positions had become redundant. A critical meeting was
convened by Smit on 31 December with members of the various departments falling
within the technical division and at which, Smit testified, he described to them
in detail the new structure which had been approved and was to be implemented
and in which he identified the positions which had in consequence become
redundant.

Later the same day Nell telefaxed a letter to the Managing Directors of the
Driefontein Consolidated, Kloof and Free State Mines and all mine managers,
identifying the specific positions and their employment levels which had become
redundant and requesting information as to whether any of the persons thus
affected could be placed at their mines. The association representative, Dye,
was similarly informed by Bloom.

It is common cause, as it emerged in the course of the following few days, that
none of the affected persons could be accommodated in any of the other
operations within the Goldfields Limited Group. On 5 January therefore, Nell, in
his capacity as Mine Manager, addressed a letter to each of the Applicants, in
essence in identical terms.

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Each was informed that his service with the company was being terminated as a
consequence of the "downscaling of operations, due to operational requirements
and gold price constraints" and the necessary "review of the company's
employment position. These included a notice period of thirty days, the
severance benefits to be paid and ancillary aspects relating to housing, medical
aid, loans and the position regarding company vehicles. It is in my view
apposite to record at this stage that the evidence which I have reviewed was
presented viva voce , with reference where appropriate and relevant to
substantial documentation before the Court, solely by the Respondent's two
witnesses, Messrs Bloom and Smit.

None of the Applicants testified and nor was any other form of direct evidence
adduced on their behalf.

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The Applicants' case is structured solely on inroads into the validity, and
concessions submitted to have been extracted in the course of, the Respondent's
testimony by way of cross-examination. The Applicants contend that their
retrenchments were both substantively and procedurally unfair and in their
Statement of Claim, identify seven specific areas of dereliction on the part of
the Respondent in that context. None of them was privy to the conclusion of the
retrenchment agreement between the Respondent and the D-Band Forum.

The majority of the Applicants were only apprised of their possible
retrenchments when they received the letters from the Respondent to which I have
earlier referred, informing them of the termination of their services.


BATTLE OF DRIEFONTEIN

They were not consulted regarding the new structures of the affected departments
which were presented to them at the end of December The Respondent, they
contend, "failed to appreciate the uniqueness of the positions" of the
Applicants and should have advised them, at a far earlier stage, that they would
be affected by the restructuring. The Respondent's selection criteria were
meaningless in relation to the positions held by the Applicants. The Respondent
failed to disclose relevant information to the Applicants to enable them
properly to consult and finally and addition to those areas of alleged
non-compliance with s of the Labour Relations Act ,- "the Act".

The issues. The primary object was not to plant the British flag at Pretoria and
Johannesburg. These two things might be the result of the war, but they were not
the primary objects of the Government policy. The objects which he wished to see
attained, and which he would pledge himself to give the utmost support to the
Government in attaining, were, first, equal rights between all white men in
South Africa, and by that he meant that never again should a situation arise in
any part of the British sphere in which a modern industrial community should be
placed under the heel of an antiquated minority which was dominated by prejudice
and governed by corruption.


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The second object was that never again in South Africa should it be possible for
arsenals to be formed or an accumulation of military material under any control
except British control. That was the end to be attained, and to that end the
Government would have support. On the 3rd of February Mr. Bryce expressed his
opinions. He affected to disbelieve that there had been any Dutch conspiracy to
drive the British from South Africa, and considered that, owing to the menace of
the Government in the arrangement of negotiations, the meek Boer had no resource
but to prepare for war.

Goschen admitted the gravity of the situation and the responsibility of the
Government en masse. The Cabinet, he decided, must stand or fall together. The
Admiralty, in acceptation of its responsibility, had assisted the army with
heavy guns without weakening its resources.

Lastly, he touched enthusiastically on the exhibition of Colonial loyalty:—.


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On the 14th male dating in Driefontein South Africa Boers still continued to
buzz about after the fashion of mosquitoes—now advancing, now retiring, worrying
and annoying, but never coming boldly to the attack. As to the Defence Committee
of the Cabinet, of which the right hon. Daniela and extremely privileged suburbs
of profiles and extremely privileged suburbs of 18 only because you had was
traveling abroad. A small cavalry patrol had entered Jacobsdal, which town was
found to be full of wounded, including many of our own invalids from Rensburg.
Balfour distinguished. Osfontein Saturday, March 3, Dear Mother No doubt you
will wonder how I am getting on - we have had a good battle last week called
Paardeburg, we captured a lager as we call camp of Boers, and killed many more,
we have had several other small battles but not as large as Paardeburg. We must
now watch the progress of the other portions of the force who were actively
engaged in taking their share in the huge undertaking. However, being too
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Modimolle Nylstroom rental cars. Lord Landsowne replied that the seventh
division would embark on January 4, which it did. The possibility of
retrenchments as an element of the exercise was in a broad context raised as
early as 3 March when, at a meeting specifically recorded as being the first in
the process required by s of the Act, the Mine Manager indicated that
consultations on the issue should start as soon as possible, having regard to
the urgency of a situation in which the Respondent "could not sustain any more
serious financial losses. The General and his staff followed at 4.

They have been supporting us with unstinted loyalty and unstinted generosity.
There has been a spirit shown by the Colonies of affection to the mother country
which has been the admiration of the world. May we not suggest that that
unstinted loyalty and that unstinted generosity is to some extent [Pg 10] a
reward for the consideration which has been shown the Colonies for some time
past; and is it not right to remember that for years there has not been a
Secretary for the Colonies who has so endeavoured to win the affection of the
Colonies as the right hon.

You tax us with not having shown foresight and judgment. At all events our
treatment of the Colonies has ensured, not their loyalty—that will always be
there—but the enthusiastic impulse of the Colonies to come to the assistance of
the mother country. We have a great work to do; we want to do that work, and now
hon.

If hon. Supposing there should be a division which could be called a bad
division for the Government, what would the cheers which would greet that
division mean? If the war is not successful, sweep us away as men who have no
judgment, but do not lame the arm of the Executive Government when they have
such a work on hand as we have got to do. There has been patriotic co-operation
between us and some of the Liberal Party.

We thank them for it. I believe this is a Parliamentary bad dream—an interlude
between the patriotic attitude of these gentlemen a few weeks ago and the
patriotic attitude which I hope we may look forward to when this debate closes.
They have assured the country they will support us in going forward. I thank
them for that, for it is more important than the petty criticisms to which we
have been treated.

We are the trustees of the nation for the work that has to be done. The nation
will support us, I believe; and so long as we receive that support, God willing,
we will fulfil our task. The annexation of the two Republics would compel us to
very greatly increase our already enormous military expenditure, and it would
not give us any advantage commensurate with the difficulties of administration.

He had no desire to press his own views, which were singular, and certainly not
popular, on that side of the House. He only pleaded that this question might be
left open, and that Ministers might not pledge themselves to a course which
would involve so great a sacrifice.

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While he agreed generally with the doctrine of Cabinet responsibility, he
considered that the real responsibility for the war lay with the Colonial
Secretary. The Prime Minister, in whom all England put the greatest confidence,
having many other things to deal with, and being distressed by domestic
anxieties, might not have been able to attend so closely as he otherwise would
have done to South African affairs; but it could not be gainsaid that there were
two men, one in this country and the other in South Africa, who must be
associated with the beginning of the war.

He wished that the highest sentiments of patriotism would induce those two men
to leave to others the positions they now occupied. He believed that the
difficulties involved in a solution of the questions arising out of the war
would be increased by the fact that the lines of communication and action in
South Africa were in the hands [Pg 11] of the Colonial Secretary and Sir A. He
had not a word to say about the honesty of these two gentlemen; but if, for a
few weeks or a few months, in this grave national crisis and time of deep
anxiety, others could take their places—if the Prime Minister himself would take
under his own control the communications of the Colonial Office with South
Africa, and if Lord Rosebery would give his services to the country, and go out
to South Africa to assist in a solution of the difficulties, it would be a
sacrifice not too great to ask even from the greatest men among us, and one for
which the country would be very grateful.

He had said that he was not going to make a controversial speech. He did not
think he had. If he had, it had been with no intention of personal attack or
party bitterness, but with the deep conviction that in deciding on the great
issues with which Parliament had to deal we had to consider not only the things
of to-day but the things of the future. Sir William Harcourt dilated on the
indomitable energy of a free people fighting for their independence, praised the
gallantry of the troops, and blamed the Government for being led by the opinions
of the authors of the Jameson Raid, to which the Colonial Secretary made
dignified reply.

Finally he questioned—. Not by denying the mistakes, but by saying what we have
done and what we are doing to repair them. You say we sent too few troops. We
are pouring troops into South Africa, and, as you have been told, in a few weeks
you will have an army of , You said we were forgetful of the need for mounted
men. We have been increasing the number of horse infantry until in a very short
time the number of mounted men in the British forces will be almost as great, if
not as great, as the total number of mounted men in the Boer army.

You say our artillery is deficient and not heavy enough. We have sent battery
after battery, until now you have an unexampled force of that arm. We have at
the same time added a number of heavier guns. When the war began, no doubt the
needs of the war were under-estimated at that time; it is part of the same
mistake. We failed to respond as we ought to have done to the splendid offers
that came from our Colonies. We accepted enough to show how much we valued their
assistance, but we hesitated to put on them any greater strain than necessary.

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