Global Whistle-blower Management Guidance

Global Whistle-blower Management Guidance

The Global Whistle-blower Management Guidance helps identify potential approaches to protect the confidentiality of the identity of any individual who raises a concern or question or reports or provides information regarding ethics matters (“Whistleblowers”), to enable the appropriate division to conduct an appropriate, fair and thorough investigation and post-reporting event monitoring.
The purpose of the guidance is also to ensure follow up and monitoring of Whistleblowers such that retaliation resulting from reporting concerns, providing information or raising questions can be easily identified and dealt with.

Compliance Investigations Triage Matrix

Compliance Investigations Triage Matrix

The Compliance Investigations Workflow Triage helps categories workplace misconduct. Some of the misconduct warrant formal investigations; others less formal measures by relevant functional units or Human Resources. Complaints regarding workplace conduct fall into several categories. These include complaints that may violate the Code of Business Conduct and Ethics or legal requirements, allegations involving other policy violations, and concerns regarding workplace conduct more generally. This Triage Matrix identifies the division of labour in addressing these various concerns.

Anti-Bribery and Anti-Corruption Procedures

Anti-Bribery and Anti-Corruption Procedures

This Procedure implements the Anti-Bribery and Anti-Corruption Policy of Barrick Gold Corporation. This Procedure defines required processes in relation to relationships with, and payments to, government officials. It further defines contracts and agreements with governments, government officials, or third parties which must be reviewed and approved by the Legal Department prior to signing. This Procedure only applies to relationships with governments and individual officials and does not apply to private commercial relationships except as provided.

Anti-Bribery and Anti-Corruption Policy

Anti-Bribery and Anti-Corruption Policy

The purpose of this Anti-Bribery and Anti-Corruption Policy is to reiterate Barrick’s commitment to full compliance by the Company, its subsidiaries and affiliates, and its officers, directors, employees and agents with Canada’s Corruption of Foreign Public Officials Act (“CFPOA”), the U.S. Foreign Corrupt Practices Act (“FCPA”), and any local anti-bribery or anti-corruption laws that may be applicable. This 4-page document supplements the Code of Business Conduct and Ethics and all applicable laws and provides guidelines for compliance with the CFPOA, FCPA, and Company policies applicable to Barrick operations worldwide.

Anti-Bribery and Anti-Corruption Procedure: Manual For Authorized Approval Employees

Anti-Bribery and Anti-Corruption Procedure: Manual For Authorized Approval Employees

This manual has been prepared to provide guidance to Authorized Approval Employees as they evaluate requests for approval of high-risk payments and transactions with government officials this is to ensure legal compliance. Under the Procedure, two levels of approval are required before something of value covered by the Procedure can be provided to a government official: (1) A request must first go through its normal approval chain as defined by the site, country, or functional unit (2) If approved in the normal approval chain, the employee overseeing the request must then seek further approval from an Authorized Approval Employee.