This document serves as a Guide for Barrick Gold employees when having meetings with government officials. This guide serves to further reiterate the companies zero-tolerance to corruption and helps to ensure best practice when having these meetings.
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.
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.
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.
This Policy sets out Barrick Gold’s expectations and requirements relating to the prohibition, recognition, reporting and investigation of suspected fraud, corruption, misappropriation and other similar irregularities. This document shows Barrick’s commitment to protecting its reputation, revenues, assets and information from any attempts of fraud, deceit or other improper conduct by employees or third parties.
This document provides guidance on giving and receiving gifts (including meals and entertainment) to or from private entities, such as vendors, potential vendors and consultants.