Guidance on Reporting Human Rights and Significant Code of Conduct Grievances To The Legal Department

Guidance on Reporting Human Rights and Significant Code of Conduct Grievances To The Legal Department

The purpose of this Guideline is to provide guidance to community relations grievance officers or others who may receive community or operational-level grievances or complains (e.g. employees in human resources, security and exploration) concerning the escalation to the legal department of human rights and/or significant code of conduct issues brought to their attention. There are a number of ethical issues that need to be escalated to managers or grievance officers while all other potential non-critical human rights issues can be addressed through normal grievance processes. This guide helps identify issues that need to be escalated.

Global Standard and Procedures for Extractive Sector Transparency Measures Act ( ESTMA ) Reporting

Global Standard and Procedures for Extractive Sector Transparency Measures Act ( ESTMA ) Reporting

The Extractive Sector Transparency Measures Act (ESTMA) requires companies that are engaged in the commercial development of oil, gas, or minerals to publicly disclose specific payments made to all governments in Canada and abroad. This includes in-kind payments and attribution payments. This document defines the requirements to help ensure that the report for ESTMA are properly prepared, supported by adequate documentation, reviewed and approved to allow for accurate reporting of payments.

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.