compliance-program

Barrick has put in place a human rights compliance program to operationalize our corporate policies and help us meet our commitment to respect human rights everywhere we operate.

The compliance program (PDF) applies on a global basis to all of our employees and Barrick-operated sites. Its purpose is to ensure that our corporate values are followed.

Accountability & Governance

Based on the belief that human rights reflect a set of international legal rights, and consistent with Principle 23 (c) of the Guiding Principles on Business and Human Rights (PDF), our Office of the General Counsel (OGC) currently provides general oversight of the human rights program.  However, the program is primarily implemented on a local basis, where accountability for conduct consistent with our human rights requirements also rests. The program seeks to be consistent with leading international standards, including the UN Guiding Principles.

Barrick strives to comply with our human rights obligations by approaching human rights as a form of governance. Specifically, we believe that every functional unit, office, and site plays a role in our respecting human rights. Under our program, the OGC works with relevant internal groups and local operating units to help them consider international human rights norms in their conduct, and in developing policies, procedures and management systems. In this way, we try to operationalize human rights in ways most relevant to each area of the business, and maximize the manner in which human rights are integrated into our daily practices. These policies are reinforced through training programs, visible management support, third-party due diligence, external assurance, and a disciplinary approach that does not tolerate human rights violations.

Through this approach, Barrick seeks to carry out its commitment to employ a workforce that respects human rights and is trained to recognize and report human rights violations. We are also committed to providing equal opportunity and freedom from discrimination for employees, working to eliminate all forms of forced and compulsory labor, and supporting the effective abolition of child labor.

Formal corporate oversight of the program begins at the Board of Directors. The Corporate Responsibility Committee of the Board of Directors, composed of four independent board members, includes within its mandate oversight of the human rights program. The OGC provides an update on the human rights program to the Corporate Responsibility Committee of the Board each quarter.

Barrick also has a Business Plan Review (BPR) meeting every week, a reporting session that includes corporate functional units and sites. The BPRs are overseen by Barrick’s President and Chief Operating Officer. Once per month, at the BPR the OGC reports on how the human rights program is progressing against its relevant goals and on issues that might prevent the program from achieving its objectives. Each site and advanced project also must report in the BPR on license to operate issues, which are defined to include the human rights program. The BPRs provide a transparent approach to identifying progress, challenges and concerns, including with respect to human rights, which can be understood and addressed by the executive senior leadership.

In 2012, we also established a Corporate Social Responsibility Advisory Board to provide Barrick’s senior executives with external advice and guidance on emerging CSR issues and trends and feedback on our performance. The board includes highly respected figures from different disciplines: Aron Cramer, Robert Fowler, and Gare Smith, with John Ruggie serving as a special consultant. Chaired by Barrick’s President, the board convenes twice per year, and as part of its mandate it receives updates on issues related to human rights matters at Barrick. Advisory Board member biographies and Advisory Board meeting summaries are available here.

Assessing Impacts on Human Rights

Assurance and verification are important tools to help Barrick operate its human rights program effectively. Given Barrick’s size and the diverse locales in which it operates, no single process can provide a full picture of the company’s human rights impacts at any given location, much less around the world. We therefore take a holistic approach to gaining a robust view of our overall human rights footprint. We conduct a variety of internal and external audit and assurance activities regarding the human rights program.  The results are examined over a multi-year period, to identify trends and changes.  We also consider the findings in conjunction with information generated by other processes, such as through our enterprise risk management process, internal audits, grievances, hotline reports, our third-party annual social assurance process and community engagement programs, engagements with in­ternal and external stakeholders, and our investigations into incidents. 

Human Rights Assessment Methodology

One of the cornerstones of our assessment efforts is an independent, stand-alone human rights assessment program for Barrick-operated properties. The assessments are conducted by Avanzar, a highly respected independent consulting organization that focuses on human rights-related assessments. Avanzar assesses the actual, potential, and perceived human rights risks and impacts at every high-risk Barrick operation and advanced project. Avanzar assures its independence by not providing implementation guidance or ongoing advice, or otherwise engaging in activities in which it might assure work that it performs. Fund for Peace, a well-regarded NGO that works to prevent conflict and human rights abuses, has served as an external and independent advisor to the company in this project. Their role has included reviewing and editing the assessment tool being used, providing guidance on the assessment plan, reviewing the reports, and discussing follow-up priorities. Professor John Ruggie, former UN Secretary-General Special Representative for Business and Human Rights, may also provide advice and guidance on discrete issues associated with the assessments. Finally, several years ago, we developed a partnership with the Danish Institute for Human Rights, from which we have received detailed assessments of applicable country-level laws and the extent to which those laws are implemented, which has further informed our assessment approach in the locations in which we operate. Those assessments are available at Human Rights and Business Country Guide.

The third-party assessments of Barrick-operated properties are conducted in reference to an assessment tool that covers dozens of individual human rights and hundreds of individual indicators. The tool is far more extensive than any commercial tool currently available. The tool focuses on seven categories, reflecting the most significant inherent risks of negative human rights impacts that we and Avanzar have identified.  We have identified those risks through the holistic process for assessing our human rights footprint identified above.  That process includes examining country-level risks and impacts, and reviewing issues and incidents that other extractive companies have faced locally and globally.  These inherent risks are common for large mining companies, and are: (1) labor and working conditions; (2) indigenous peoples;  (3) economic, social and cultural rights; (4) environment and health and safety; (5) land rights; (6) security; and (7) anti-corruption. Issues related to supply chain, third parties, and vulnerable peoples also are embedded throughout these seven categories. 

Avanzar’s methodology consists of documentary and desktop reviews to identify areas of greatest risk and concern at a country and site level, determining the assessment scope for each site, semi-structured interviews with Barrick employ­ees (on-site and by phone), semi-structured interviews with key external stakeholders (on site and by phone), and draft report preparation for the OGC. The process includes substantial internal and external stakeholder engagement to gather information regarding perceived human rights impacts and to verify human rights risks and impacts identified. Avanzar’s engagement methodology applies recognized qualitative research methods that include interviews, focus groups, and observation to capture stakeholder concerns and issues related to Barrick’s operations. Key providers of information include specific external rights-holders whose rights may be impacted by the mine, such as communities living near the operation, individuals who have been resettled, local employees of mine contractors, and individuals who have lodged grievances with human rights implications. 

After information is gathered and assessed against the tool, the OGC shares a draft report with the external independent reviewer, and then with local management and relevant functional unit employees who may be involved managing salient issues.  Those comments are then reviewed and integrated, and the OGC issues a final report and proposed action plan.  The proposed action plan is then reviewed, adjusted and adopted by local management and other relevant personnel, who may be involved managing the pertinent issues. Once finalized, the process calls for action plan items to be included in a data system that automatically follows up with the assigned personnel to create accountability for executing the plan.

Presentations on the reviews and follow-up are reported on a monthly basis during business plan review (BPR) sessions with senior company leaders, and quarterly to the Corporate Responsibility Committee of the Board of Directors.  Responses and feedback to issues and concerns identified by local external stakeholders are most often addressed by community relations personnel, management, and others at each individual site.  To the extent tensions arise between preventing mitigating impacts and other business objectives, those tensions may be resolved through dialogue at the Board Committee level, during the BPRs or special action reviews (SARs) that may follow BPR sessions, or in discussions between the OGC and relevant business units.

At this point in the human rights assessment program (mid 2016), all high- and medium-risk sites operated by Barrick have been assessed at least once and the highest-risk operations have been assessed more than once. 

Integrated Approach

Our human rights assessment program is distinguished from one-time “stand-alone” assessments, such as predictive assessments conducted during the feasibility and pre-feasibility stages of a project, and functional unit management system assessments designed to ensure compliance with policies and procedures at mine sites. However, consistent with our holistic approach, we seek to create synergies with other assessments that relate to human rights, to help identify most accurately and effectively our human rights impacts and risks. Our compliance with the Voluntary Principles, for instance, is assessed regularly through multiple review channels, with the outcomes considered by the company and Avanzar. Internal assurance work for functional areas whose activities present salient human rights risks, including community relations, health, safety, and environment, also occur regularly.

2015 Assessment Program

In 2015, Avanzar conducted a human rights assessment at the Pueblo Viejo mine, in the Dominican Republic (a high risk site).  As in prior years, the assessment was conducted simultaneously with, and to some extent in conjunction with, internal Community, Health and Safety, Environment, and Security audits, which were conducted by auditors from the corporate office. 

The assessment identified several areas of potential negative human rights impacts, including in relation to monitoring contractor working conditions and their compliance with domestic labour laws and international standards, gaps in noise monitoring by the site, impacts on a local river, and sexual harassment. The assessment also identified steps the site has been taking to address, mitigate and prevent these and previously identified risks, which include:

  • Due diligence, including human rights-related due diligence, on new and renewing vendors, and self-certification of Barrick’s Supplier Code of Ethics
  • Investigations and audits of contractors where complaints are lodged (including complaints by contractor employees)
  • Dismissing contractors who fail to comply with our policies or the law
  • A risk assessment in the supply chain
  • Environmental monitoring, along with policies, procedures and a management system that includes audits and assessments
  • Enhanced human resources policies, procedures and trainings related to sexual harassment and discrimination more generally

Global Human Rights Impacts

On a global basis, we have identified seven human rights with the greatest potential to be negatively impacted, whether caused or contributed to by, or directly linked to, Barrick’s operations.  In consultation with key stakeholders and as a result of our internal risk identification procedures and third party assessments, we have identified the following salient risks: the Right to a Healthy Environment, the Right to Water, the Right to Just and Favorable Conditions of Work, the Right to an Adequate Standard of Living, the Right to Adequate Health, the Right to Life, Liberty, and Security of Person, the Right to Property, and the Right to a Safe Working Environment.  In addition, assessment findings from past years (some of which relate to sites Barrick no longer operates) have included those related to impacts on the quality and quantity of water, community awareness of environmental risks and impacts, use of force by security personnel, negative impacts related to in-migration at certain locations, contractors and suppliers (including their awareness of site grievance mechanisms and their respect for the rights of workers to form unions), unequal treatment between nationals and expatriates, and industrial hygiene programs.  Overall, for the sites Barrick presently operates, the negative risks and impacts identified in 2015 and prior years do not seem to indicate broader policy or procedural weaknesses, but rather isolated implementation issues and issues arising from in-migration at several locations. 

Past assessments also have identified examples of good practice and improvements in areas related to Barrick’s salient risks, including in relation to resettlement and consultations, training and vetting of security personnel, participatory water monitoring initiatives, and working with governments to increase access to potable water. 

Other previously identified steps that that Barrick has undertaken to address noted risks are extensive, examples include:

  • Automating corrective action plans so that appropriate personnel receive timely notifications if the action plans are delayed;
  • Strengthening the supplier due diligence programs and onboarding process;
  • Enhancing awareness and trust in the implementation of site grievance mechanisms;
  • Providing human rights training for grievance officers;
  • Conducting certain health impact assessments;
  • Continuing a partnership with the White Ribbon Campaign to address gender-based violence at our mine sites;
  • Providing third-party training for public security forces;
  • Working with international partners to help strengthen the judicial system;
  • Increasing the use of alternative screening methods during employment onboarding;
  • Improvements to the training of security guards in ways that include a stepped up use of scenarios;
  • Strengthening the culture of whistle blowing, transparency, and responsibility;
  • Improving the approach of the Community, Health, Environment, Safety, Security (CHESS) assurance work related to health and safety.

SALIENT RISK

MITIGATION MEASURES INCLUDE

Right to a Healthy Environment, Right to Adequate Health

Enhanced monitoring and communication with local communities around environmental impacts

Right to Water

Participatory water monitoring activities, working with government to increase access to water

Right to Just and Favorable Conditions of Work

Focused efforts on contractor employment processes

Right to Life, Liberty and Security of Person

Improvements to the training of security guards in ways that include a stepped up use of scenarios; providing third-party training for public security forces; continuing a partnership with the White Ribbon Campaign to address gender-based violence at our mine sites

Right to Property

Implementation of resettlement programs

Right to a Safe Working Environment

Improving the approach of the Community, Health, Environment, Safety, Security (CHESS) assurance work related to health and safety

A summary report of the 2012, 2013, and 2014 assessments, which contains more detail about Barrick’s past assessments, is available by request to s.jimenez@barrick.com.

Human Rights Education & Training

The tone from the top matters when it comes to deepening a culture of respect for human rights and compliance. Executive management seeks to reinforce the importance of respecting human rights by championing the human rights compliance program, and ethical behavior more generally through different avenues, such as executive addresses, town hall meetings, and global emails. Senior managers have introduced and attended training sessions, and we use internal avenues – newsletters, flyers, posters, and social media – to discuss different aspects of our human rights program on a regular basis.

We attempt to begin educating employees on our human rights approach before employment begins, including references to our Human Rights Policy in job applications, and conducting due diligence and vetting, including through asking questions related to human rights issues on our global employment questionnaires. Employees in positions where human rights risks may be most prevalent, such as security, receive heightened vetting and due diligence. New Barrick employees also will have human rights clauses built into their contracts and offer letters and are to receive basic human rights training as part of their onboarding process. All security personnel are trained on human rights policies and procedures.

In 2014, the OGC created a Guidance for Employee Mapping, a document that helps sites identify employees who may be more exposed to certain human rights risks and who should receive enhanced, in-person human rights training on an annual basis. Certain employees are required to sign annual certifications stating that they are not aware of potential unreported human rights violations and that they will abide by Barrick’s Human Rights Policy. We also developed “train the trainer” materials in 2011 and have held numerous workshops that allow regional and mine-site employees to deliver effective human rights training in their areas.

Finally, Barrick’s online Code of Conduct training includes a dedicated human rights component.

Training is targeted to ensure functional groups, such as security, receive more extensive training in areas where human rights risks are found to be present. For certain functional areas, such as security and community relations, Barrick tracks the effectiveness of this training through internal assurance processes and other means.

More than 6,300 Barrick employees received online human rights training in 2015, comprising approximately 6,300 hours of training. In addition, more than 1,400 security personnel (100% of security employees) received dedicated, live human rights training comprising more than 10 hours of instruction. As a result, in 2015 more than 22,500 hours of human rights training was conducted across the company.

Increasing Stakeholder Awareness

Barrick has pledged to be transparent about its human rights program. We continue working to improve external awareness of our performance through updates to our website, in our annual Responsibility Reports, in presentations at conferences and workshops, in multi-stakeholder initiatives, and in specific communications with impacted and interested stakeholders. 

Examples of these communications include:

  • Distributing booklets regarding human rights to local community members and government entities;
  • Performing community surveys on violence to gain feedback on how to improve security arrangements;
  • Engaging public officials and community authorities on how to promote respect for law and order, reduce conflict, enhance and strengthen justice service delivery;
  • Providing education on the impacts of land purchase and sales;
  • Presenting on our programs at business and human rights conferences;
  • Sharing information during business and human rights working groups and roundtables;
  • Participating in industry and multi-stakeholder initiatives;
  • Including key aspects of our human rights performance in our Responsibility Report;
  • Publishing updates on key aspects of our program through reports and other materials;
  • Engaging with external stakeholders in response to specific questions and concerns.

Security & Human Rights

Barrick has developed a comprehensive Security Policy (PDF) and Security Management System (PDF) designed in significant part to respect human rights while protecting persons and property associated with our mines. On a global level, as with many other extractive companies, we consider security-related human rights impacts to be among our most salient risks.

The VPs guide and dictate our overall approach to the provision of security on a global basis. That includes our engagement with host nation military and police representatives who provide external security and response assistance, as well as private security providers, reinforcing human rights principles in contractual requirements. The Voluntary Principles also help our formulation of guidelines and training on the use of force. In geopolitically complex regions, Barrick’s security personnel receive mandatory human rights training and training in the requirements of the Voluntary Principles. From 2012 to 2014, Barrick was a board member of the Voluntary Principles Initiative. The company rejoined the Steering Committee in 2016.

For more information about Barrick’s in-depth approach to security and our use of the Voluntary Principles, see Security.

Suppliers & Human Rights

Barrick expects consistently ethical behavior from our suppliers and contractors. We strive to do business only with those third parties who share our respect for human rights and seek to educate potential suppliers on our human rights expectations before we enter into a relationship with them. We include human rights due diligence as part of our global onboarding standard for third party vendors, and request that suppliers abide by the Barrick Supplier Code of Ethics, which incorporates many elements of Barrick’s Human Rights Policy. Where we determine it is appropriate, we conduct enhanced due diligence on prospective suppliers related to human rights and have developed extensive materials to conduct due diligence using a variety of methods.

Once Barrick agrees to do business with a supplier, relevant contracts may contain human rights compliance provisions, and we may provide focused training to certain suppliers. Under our Human Rights Policy, suppliers are expected to report human rights issues of which they become aware, and we may ask relevant suppliers to periodically provide certifications that they are not aware of any unreported human rights allegations in their work. Where appropriate, we investigate the behavior of existing suppliers and contractors related to human rights issues.

For more information about Barrick’s supply chain practices, see Supply Chain.

Labor & Human Rights

Barrick is committed to ensuring that our employees respect human rights and are trained to recognize and report human rights violations. We are also committed to providing equal opportunity and freedom from discrimination for all our employees, to upholding the elimination of all forms of forced and compulsory labor, and to supporting the effective abolition of child labor.

Barrick’s Policy with Respect to the Declaration of Fundamental Principles and Rights at Work, which is closely aligned with the International Labor Organization’s declaration, was adopted in 2012.  Barrick also created a global sexual harassment standard to further underscore the company’s steadfast position against sexual harassment in the workplace.

Our human rights expectations are conveyed to potential employees before an individual is employed by Barrick, including through questions on global questionnaires and employment applications, through vetting and/or background checks for employees in positions that can potentially cause significant negative impacts on human rights, and through employment letters and contracts that contain reference to our expectations. Barrick also has created dedicated programs at a number of sites to address sexual harassment, which has included training, reporting, monitoring and other steps to reduce the likelihood of harassment and assist victims when it occurs.

For more information about Barrick’s policies toward labor and human rights, see Our People.

Environment & Human Rights

A mine can affect the physical environment — including the land, air, water and other important resources that we share with others. We recognize that these actions we can potentially cause or contribute to negative impacts on human health and livelihoods, as well as that access to clean water can itself raise human rights concerns. That is why Barrick is committed to minimizing and mitigating our impacts on the environment in the first place, and where they do occur, to working towards effective reclamation and remediation.

Barrick’s Environmental Management System aims to reduce potential environmental impacts by establishing and applying proven management practices. Barrick´s Environmental Policy clearly sets requirements to communicate our environmental commitments to employees and host communities. Our Environmental Management System is primarily based on a compliance and risk-based approach in which we first assess potential impacts and environmental consequences, and then evaluate how to avoid, mitigate, or control these impacts. Barrick typically puts in place several layers of environmental protection and engages in advanced planning against possible future events.
For more information about Barrick’s environmental stewardship, see Environment.

Community Development & Human Rights

Barrick recognizes that the scope and breadth of human rights is far reaching. As stated in the Universal Declaration of Human Rights, “everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services,” and “everyone has the right to education.” Barrick makes an active and positive contribution to human rights through programs that provide access to education, clean water, and health services for the communities neighboring our mines. We are also committed to promoting health and safety practices for our employees. For full details on our contributions to the socio-economic development of the communities where we operate, see Social & Economic Development.

Grievance Mechanisms, Investigation & Remediation

We are deeply aware that even businesses that strive to act responsibly can contribute to negative impacts on human rights. At Barrick, we have developed readily accessible tools by which both employees and local communities can notify Barrick of their concerns, including those related to human rights.

Barrick has internal global procedures that outline the mechanisms that employees can use to notify local and corporate management of potential human rights violations, and specify how alleged violations are to be investigated. Employees are routinely encouraged to use Barrick’s Compliance Hotline to report information related to any potential human rights violations they might see or hear about.

We also have policies and procedures so that every community in which we operate has simple, accessible grievance mechanisms through which to provide feedback and request remediation for legitimate concerns. Grievance channels vary by site, and include message boxes, telephone hotlines, town hall meetings, supervisors (for employees), and direct contact with Barrick employees.

Our human rights assessments include a review of how effectively the grievance mechanisms escalate potential human rights concerns. We also have our grievance mechanisms internally audited for implementation and effectiveness during regular audits of our Community Relations Management System (CRMS) and externally assessed against the UNGPs effectiveness criteria.

Mandatory Reporting and Investigation

Barrick employees are required to report all potential human rights risks or impacts of which they become aware, regardless of whether they believe the allegations to be true. Our procedures also require that all human rights allegations be investigated, with the nature and extent of the investigation dependent on the circumstances. For serious potential human rights breaches at our sites, we strive to ensure independence in our investigations. Those investigations may be conducted by retaining external investigators or through our corporate investigations unit, which is located at corporate headquarters. This unit is jointly supervised by the OGC and Operations Officer and may report on investigative activity to the Board of Directors. Regardless of the result of the investigation, the company endeavors to respond to the complainant and provide him or her with progress updates.

Remediation

When negative human rights impacts are identified, we strive to take a culturally appropriate and thoughtful approach to communication and remediation. We are sensitive to the importance of collaborative stakeholder and victim input in the development of appropriate remedy, and the potential need for independence in circumstances where remediation may be appropriate. For example, a distinct human rights remediation program was developed in response to specific incidents of sexual violence at the Porgera Joint Venture mine in Papua New Guinea.  This program was in addition to the site operational level grievance mechanism.

For more information on community engagement and site grievance mechanisms, see Community.

Date Download Description
May 6, 2015 files/design/bodybg/our-approach.jpg
2014 Responsibility Report
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