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Pretoria - Lonmin unduly influenced the SA Police Service to act against protesting Marikana miners, the Farlam Commission of Inquiry heard on Tuesday.
Lonmin security risk manager Dirk Botes' participation in the police joint operations centre (JOC) was unjustifiable, said Tholoana Motloenya, representing 33 of the 34 people killed on 16 August 2012.
"You were present in the JOC at all times, you gave SAPS information. You were aware of SAPS plans and the changes to the plans," Motloenya told the inquiry's public hearings in Pretoria.
"You attended Joccom [joint operational co-ordinating committee] meetings. We are going to argue that it was completely unacceptable and amounts to Lonmin being operationally involved in the SAPS operation."
Motloenya also represents the families of three mineworkers killed on 13 August 2012. She was cross-examining Botes at the inquiry's hearings in Pretoria.
Botes said his role was to give the police guidance.
"My role was to guide SAPS and to provide adequate layout plans of the whole area. They were having their deployments across Lonmin and all the shafts," he said.
Motloenya asked why it would be Lonmin's role to do so.
Botes responded: "The guidance I gave was with regards to critical installations where the police were deploying. The guidance was to protect the installations.
"We know the area, the police were sent to Marikana from across South Africa. They had no clue where any of our installations where. I had to guide them."
Motloenya said Botes' explanation would have been acceptable if he had acted outside the JOC. Botes said a JOC called for co-operation.
"A JOC is exactly what the name is. At any JOC, police have to interact, whether they are intervening in the petrol or mining industry. I was in the JOC as a partner," said Botes.
The three-member commission, led by retired judge Ian Farlam, is probing the deaths of 44 people during the wage-related protests in Marikana.
On 16 August 2012, 34 people, mostly striking miners, were shot dead and 78 people were wounded when the police fired on a group gathered at a hill near Lonmin's platinum mine. They were trying to disperse and disarm them.
In the preceding week, 10 people, including two policemen and two security guards, were killed in strike-related violence.
Regarding 16 August 2012 police deployments, Motloenya asked why Botes was present when senior SAPS officers briefed their charges.
"What I want to know is why you were allowed to be present when the members were being briefed. You had detailed knowledge of the police plan," she said.
Botes said it was important for him to understand the police plan, and to convey it to Lonmin security guards.
"I would be aware of the police deployments. It would be no use for police to go into an area and my people are not aware of it," said Botes.
"I had to be there. That is a normal practice in any JOC. I did not have detailed knowledge of their plan. I was not part of all the briefing sessions."
Botes is expected to continue his testimony on Wednesday.
