element-1-policies-and-procedures

Our Code of Business Conduct and Ethics and Human Rights Policy reflect the key requirements of our program, which are buttressed by a range of policies, procedures and standards. 

Policies

Critical to any effective compliance program is a clear substantive policy and effective implementing documents.  In 2011, we modified our Code of Business Conduct and Ethics to include an explicit commitment to respecting human rights.  Also in 2011, we adopted a standalone Human Rights Policy, which contains the philosophical premise behind our human rights approach:  that we will respect the human rights of all stakeholders impacted by our operations. It unequivocally states, “Barrick does not tolerate violations of human rights committed by its employees, its affiliates or any third parties acting on its behalf or related to any aspect of a Barrick operation.”

Barrick does not tolerate violations of human rights committed by its employees, its affiliates, or any third parties acting on its behalf or related to any aspect of a Barrick operation.

The Policy applies to Barrick corporate offices and to every aspect of the mines and projects that Barrick operates, including all employees (on or off duty) and third-party contractors.  It further declares that a human right is one recognized by the International Bill of Human Rights.  It also mandates that we follow the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, and we maintain a separate policy specifically dedicated to implementing the Declaration.

Putting it into practice:

While creating policies is important, meeting our commitment is the bigger test. We try to meet that test by embedding human rights considerations into Barrick’s values, governance frameworks and corporate management systems. From Supply Chain and Human Resources to Security and Community Relations, Barrick considers it our responsibility to respect human rights throughout the business. Indeed, the Policy is supported by and incorporates numerous function-specific policies. These include:  the Supplier Code of Ethics, the Policy with Respect to the Declaration of Fundamental Principles and Rights at Work, the Security Management System, the Community Relations Management System (CRMS), the Anti-Bribery and Anti-Corruption Policy, the Safety and Health Management System, and the Environmental Management System.

Procedures

We also try to buttress our Human Rights Policy with a number of dedicated policies, standards and guidelines. Internally, we place great importance on reporting concerns and investigations.

Likewise, for external stakeholders, securing and maintaining our license to operate depends on our ability to listen actively and be responsive when they raise issues of importance to them.

Putting it into practice:

In recent years, a priority in Barrick’s CRMS, overseen by the Community Relations functional group, has been to require that all operations have an effective grievance mechanism in place.  Consistent with the UNGPs, Barrick’s CRMS provides all communities where we operate access to a simple and culturally sensitive process through which they can provide feedback and seek resolution to legitimate concerns. The discussion on grievance mechanisms and remedies provides additional information about this, including the number and nature of grievances received in 2016.

Another key procedure relates to reporting and investigating human rights-related allegations. A global internal procedure requires immediate reporting and escalation of information related to potential negative human rights impacts.  All information about potential human rights violations must be reported, regardless of whether it seems credible to the employee or the amount of detail that the employee might know.  The procedure also contains details on how information should be reported, and it includes an anti-retaliation provision.  We also require that all allegations of negative human rights impacts must be investigated, though the nature and extent of the investigation may vary depending on the circumstances.  Typically, for serious potential human rights breaches, we strive to create independence in our investigations.  That may be through external investigators that we retain.  It also may be through our corporate investigations unit, which is housed at our headquarters and is independent of the site or location where a breach may have occurred; the investigations unit is supervised by the Office of General Counsel and Operations Officer, and the results are reported to a committee of the Board of Directors. 

We require that all allegations of negative human rights impacts must be investigated.

Finally, we have created internal guidance documents to help employees in implementing our program.  Examples of this include guidance on how to:

  • Help detect and respond to allegations of retaliation for whistleblowers
  • Map employees for appropriate training
  • Conduct due diligence on prospective employees and institute relevant controls
  • Provide human rights remediation.     

While our policy framework has grown substantially, we are still working to identify ways to strengthen it. In 2016, for instance, in response to growing concerns about global harassment, we introduced a new harassment standard to help provide greater workplace protections. We also felt we could do more to emphasize the importance of reporting concerns in good faith, and introduced new non-retaliation guidance for human resources and legal personnel. In 2017, we also enhanced our Code of Business Conduct and Ethics to make it easier to understand and apply. As we move forward, we will continue to look for ways to improve our systems and processes.

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