ethical-business-conduct

With thousands of employees, suppliers and contractors, working in highly diverse countries, our exposure to potential incidents of bribery and corruption is real, and can present risks to companies like ours that operate around the globe.

Not only is corruption contrary to our values of integrity and responsibility, it also erodes the social fabric of the communities where we operate.

At Barrick, we demand that all of our interactions are conducted in an ethical, honest and accountable manner and in accordance with all applicable laws and regulations.

Our Approach

We have a Code of Business Conduct and Ethics (the Code), which identifies our obligations, as a company and as individuals, to comply with all applicable laws and to avoid and report bribery and corruption wherever we work.

Barrick also has a comprehensive, global Anti-Corruption Policy and Compliance Program that helps our conduct adhere to Canada’s Corruption of Foreign Public Officials Act, the U.S. Foreign Corrupt Practices Act, and applicable anti-bribery and anti-corruption laws in other countries where we operate.

Our Progress

  • Barrick has created an internal cross-functional corporate committee to help set global standards for relevant functional units, provide guidance, and help drive more effective local implementation of the Anti-Corruption Program. In 2015, the Program featured several performance highlights:
    • All (100%) of relevant employees, identified on a risk-tiered basis, received live anti-corruption training. The audit committee of the board also received periodic training in anti-corruption.
    • In total, 7,200 relevant or high-risk employees received anti-corruption training (2,300 live & 4,900 on-line). In “effectiveness” testing through Sarbanes-Oxley scores, 98 percent confirmed basic knowledge of our anti-corruption policy.
    • Implementation of employee and vendor onboarding standards.
    • Anti-corruption baseline and risk assessments at three Barrick locations.
    • Extensive messaging (tone from the top) from corporate and local leaders about following the Code, Anti-Bribery Policy and relevant procedures. In “effectiveness” testing through Sarbanes-Oxley scores, 99 percent of surveyed employees confirmed their belief that Barrick is committed as a company to anti-corruption.
    • Monthly presentations on progress of key aspects of the program to global leaders during monthly Business Process Reviews.
    • Rollout of induction video for all new full-time Barrick employees.
    • Key performance indicators added to bonus metrics for all employees related to the company’s overall anti-corruption performance, plus additional bonus metrics for individual sites.
    • New on-line hotline reporting processes and case-tracking materials.
  • Each year Barrick conducts a global risk assessment of 100% of Barrick sites for risks related to corruption; we then conduct periodic in-depth site level assessments for medium and high risk sites. In 2015, these assessments identified third parties who might have unidentified or non-apparent government affiliations, such as suppliers or contractors, as a corruption risk.
  • Collective action with industry peers, local governments and civil society is an important way to make progress on challenging societal issues. To this end, we continue to participate in a number of multi-stakeholder groups, including the World Economic Forum’s Partnering Against Corruption Initiative (PACI), the Business for Peace Initiative, the UN Global Compact’s Global Supply Chain Working Group, and the Human Rights & Labor Working Group. We also led the creation of an e-book on anti-corruption compliance for the Global Compact Network Canada, participated in an anti-corruption working group for the mining industry with TRACE International, and actively participate in additional panels and conferences.
  • Code of Conduct Violations
    Barrick expects employees and directors to take all responsible steps to prevent a violation of this Code, to identify and raise potential issues before they lead to problems, and to seek additional guidance when necessary. In the past year our employees raised concerns about potential violations of the Code either through local channels or through our formal reporting channels, including the confidential hot-line.
Code of Conduct Cases
  • Code of Conduct Training
    To ensure our high expectations of ethical behavior remain as clear as possible, Barrick continued to provide mandatory training on the Code to all new employees in 2015. In addition, all employees in administrative offices, and supervisors or above at mine or project sites, are required to undertake annual refresher training on the Code. In total, approximately 6,300 employees received focused anti-corruption training in 2015.

Anti-Corruption Compliance Program

Our comprehensive global Anti-Corruption Compliance Program helps us adhere to these laws. The Program seeks consistency with the stated expectations of U.S. and Canadian regulatory authorities, and is overseen by the Audit Committee of the Board of Directors.

The program includes:

  • Detailed procedures governing government agreements, government support and higher-risk transactions, including political donations, charitable contributions, and government-related direct and in-kind support, per diems, meals, gifts, entertainment and travel; 
  • Guidance materials in key areas (including risk assessments, invoice red flags, onboarding and monitoring intermediaries, asset acquisitions and joint ventures, and government-related support);
  • Focused training and education activities;
  • Due diligence of potential and actual employees and relevant vendors;
  • Scrutiny of government intermediaries and agents;
  • Treatment of charitable contributions as higher-risk payments subject to both audits and risk assessments;
  • Frequent communications from company leaders;
  • Risk assessments and systems and process testing, focusing on higher-risk areas;
  • Diligence associated with joint ventures and acquisitions.

Reporting

Barrick expects all employees, officers and directors to identify and raise concerns about unethical business conduct, including potential bribery or corruption issues. When corruption concerns are raised, independent investigations are conducted. In support of this, we have established a clear and confidential reporting framework that:

  • Allows for employee concerns to be raised properly;
  • Includes internal procedures surrounding potential Code violations – reporting to appropriate levels of management and the Audit Committee of the Board as appropriate;
  • Includes a strong anti-retaliation statement for those who do raise concerns in a timely and good faith manner.

Under our procedures, we may voluntarily report information regarding corruption or fraud concerns and the results of an investigation we carry out to law enforcement, regulatory authorities or others, and cooperate with investigations that public authorities may undertake. We also will undertake appropriate disciplinary action up to and including terminations of employees and third parties involved in unethical business conduct.

Download Barrick’s Code of Business Conduct and Ethics.

Transparency

Barrick believes that revenue transparency and reporting on our relevant programs, whether through the Extractive Industries Transparency Initiative (EITI), the Dodd-Frank Act, or the Global Reporting Initiative (GRI), can be a powerful tool against corruption and in support of ethical business conduct.

We were the first Canadian mining company to be a signatory to the Extractive Industries Transparency Initiative. We provide detailed country-by-country information, including environmental performance, benefits to communities, and the taxes and royalties paid to governments, on our website. We also report on our programs and performance to the International Council on Mining & Metals (ICMM), the Dow Jones Sustainability Index (DJSI), through the CDP Climate Change and Water Disclosure process, and in our annual GRI-compliant Responsibility Report.

Date Download Description
May 6, 2015 files/design/bodybg/our-approach.jpg
2014 Responsibility Report
Gold  $ 1,256.20 -0.88 -0.07% Volume: February 27, 2017
ABX NYSE  $ 19.54 +0.00 +0% Volume: 13,338,300 February 24, 2017
ABX TSX  $ 25.59 +0.00 +0% Volume: 2,833,600 February 24, 2017
Gold  $ 1,256.20 -0.88 -0.07% Volume: February 27, 2017

Our vision is the generation of wealth through responsible mining — wealth for our owners, our people, and the countries and communities with which we partner.

World Gold Council Member

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