element-3-due-diligence

Given Barrick’s size and diverse operational contexts, 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 understand our overall human rights footprint.

Putting it into practice

Human rights impact assessments:  One of the cornerstones of our due-diligence efforts is a stand-alone, independent human rights assessment program for Barrick-operated properties. The program is discussed in detail here.  The assessments are conducted by Avanzar, a respected independent third-party consultancy, and focus on actual, potential and perceived impacts. Each site is assessed on a periodic cycle of two to three years, depending on risk. The focus is on continuous improvement, not a one-time identification of all risks in, say, a single six-month assessment.  A well-regarded NGO, Fund for Peace, serves as an external independent advisor on the program, and Professor John Ruggie also provides advice and guidance on discrete issues associated with the assessments.  In-depth assessments of applicable country-level risks have been provided by the Danish Institute for Human Rights.   

The human rights assessment program began in 2011, and to date, all high- and medium-risk sites have been assessed at least once.  In 2015, an assessment was conducted at the Pueblo Viejo mine in the Dominican Republic.  In 2016, assessments were conducted at the Pierina and Lagunas Norte mines in Peru and Lumwana in Zambia.  The findings are incorporated into our overall assessment of enterprise risks under our enterprise risk management system, and may be discussed during our weekly BPRs. Summary reports of the 2012, 2013 and 2014 assessments are available by request to s.jimenez@barrick.com.

Our approach is distinguishable from one-time “stand-alone” assessments.  It is also different from functional unit management system assessments, although (as noted below) we seek to create synergies with other assessments that relate to human rights to help to more effectively identify our human rights impacts and risks.

New Acquisitions and Mine Projects

We recognize that it is important for our program to extend in full to new operations that may be developed or acquired.  In the mining industry, acquisitions and dispositions of assets are common.  In addition, when sites evolve from exploration to construction to operation, their character, personnel and risks change as well.  We approach these areas in different ways.

Pre-acquisition (and disposition)
.  Under our program, we strive to conduct human rights due diligence as part of acquisitions to identify existing risks and impacts.  To that end, we have created an internal guidance document, the Guidelines for Asset Acquisition and Disposition, to assist in conducting human rights due diligence for potential asset purchases (and sales). 

Post-acquisition.  Following an acquisition, it is important that we rapidly apply, and that the acquired company integrate, the human rights program (and other international regulatory and compliance programs) into its systems. 

Pre-construction.  Before mine projects are constructed, we strive to conduct human rights assessments and include them in the Environmental and Social Impact Assessment Reports.

As operations develop.  As our operations develop, we continue to assess their human rights impacts, risks, and needs, and adjust the program accordingly. 

Internal and external audits: In addition to our human rights assessments, we conduct a variety of internal and external audit and assurance activities that bear upon 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, community and stakeholder engagement programs, engagements with site and functional leads, and our investigations into incidents. In 2016, all of our sites underwent internal and external audits that bear some relation to human rights considerations.

Employee screening: Important for any compliance program is screening potential employees whose background suggests they pose risks to the substantive principles at issue.  All potential Barrick employees receive pre-screening questions that could result in disqualification for employment based on past human rights violations. All employees undergo basic due diligence through a third-party research platform before being hired, and background checks are conducted for employees in positions of trust. Employees in positions where human rights risks may be most prevalent, such as security, also receive heightened vetting and due diligence.  In addition, job applications and/or accepted employment letters and agreements contain statements expressing our human rights expectations.

In 2016, more than 1,000 employees were onboarded and received human rights training.

Supplier screening and onboarding: Negative human rights impacts can occur as a result of behavior from our suppliers and their subcontractors. Therefore, as with potential employees, we educate potential suppliers on our human rights expectations before we enter a relationship with them. Before contracting with a supplier, we require that the supplier abide by our Supplier Code of Ethics, which incorporates the 10 Principles of the UN Global Compact and key concepts of Barrick’s Human Rights Policy and Policy with Respect to the Declaration on Fundamental Principles and Rights at Work. We also include human rights considerations in our global Vendor Onboarding Standard. This includes basic due diligence on all direct suppliers related to human rights before contracting with them, and it may include enhanced due diligence on suppliers who may have elevated risks of negative human rights impacts or who provide goods or services on-site.

Once Barrick agrees to do business with a supplier, Barrick’s Code of Business Conduct and Ethics and Human Rights Policy applies to them in their work for us, just as it does to our own employees. Our contracts with third parties typically have provisions requiring suppliers to abide by key human rights norms and Barrick policies, and we sometimes provide focused training to suppliers who have particular risks of negative human rights impacts. Under our Human Rights Policy, suppliers are expected to report human rights issues of which they become aware, and we may ask suppliers to periodically provide certifications that they are not aware of any unreported human rights allegations in their work.  To date, some 6,000 suppliers have undergone baseline due diligence. Where appropriate, we investigate allegations involving existing suppliers and engage with them in providing remediation for negative human rights impacts.  

We are continuing to look at ways to make our diligence process more efficient and effective. In 2017, we incorporated into our human rights assessments additional, more in-depth indicators related to trafficking. We are actively considering different technology solutions to streamline our processes and allow for better record keeping and monitoring. We also are continuing to work with UNICEF and UNICEF Canada to develop a Child Rights and Security Checklist, to help improve the approach for us and others regarding children’s rights in the security context and think about how to better protect vulnerable populations more generally.

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Gold  $ 1,284.70 +0.85 +0.07% Volume: August 16, 2017
ABX NYSE  $ 16.91 +0.36 +2.17% Volume: 9,399,317 August 16, 2017
ABX TSX  $ 21.34 +0.23 +1.09% Volume: 2,373,284 August 16, 2017
Gold  $ 1,284.70 +0.85 +0.07% Volume: August 16, 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.

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