Barrick’s Commitment to Global Norms and ESG Ratings Agency Engagement

This webpage was originally published in September 2025. It has subsequently been updated to reflect recent engagements with MSCI and is applicable as of November 19, 2025. 
 

Introduction

Barrick Mining Corporation (Barrick) is a gold and copper multinational with a footprint that spans the globe, and with a high proportion of assets in the developing world. As a leader in sustainability, we are committed to partnering with our host countries and communities to transform their natural resources into tangible benefits and mutual prosperity, while implementing industry best practice to manage our impacts. We pride ourselves in being honest and transparent, and open to engagement, and have worked hard to build partnerships on the ground where we operate.

Barrick’s approach and commitment to responsible mining is codified in our policies which are informed by international best practice, and include, among others, the UN Guiding Principles on Business and Human Rights (UNGPs), the Universal Declaration of Human Rights, the ILO’sInternational Labour Organization Core Conventions, the OECD Guidelines for Multinational Enterprises, the IFC Performance Standards and aspect-specific internationally recognised best practices. Barrick reports on its sustainability performance through its annual Sustainability Report and linked performance data.

Barrick has also endorsed and adopted voluntary principle-based best practices. These include industry best practice Responsible Gold Mining Principles (RGMPs)World Gold Council, the ICMM’s Mining Principles Performance Expectations and Towards Sustainable Mining (TSM)TSM applies only to the Hemlo and Veladero operations, which are located in Canada and Argentina respectively standards, as well as the United Nations Global Compact (UNGC) and the Voluntary Principles on Security and Human Rights (VPSHR)Voluntary Principles Initiative. Barrick reports its conformance with the RGMPs and Mining Principles in its annual Sustainability Report, with the VPSHR through the Voluntary Principles Initiative (VPI), with the TSM through the Mining Association of Canada’s reporting framework, and a Communication on Progress of the UNGC on both the Barrick website and UNGC website.

Barrick has endorsed and adopted these Principles because it believes they align with our values and reflect best practices that aim to achieve responsible business and set the foundations for long term sustainability. Barrick’s policies, strategy and standards incorporate these Principles and are embedded in all levels of the organization.

Barrick has been a proud signatory of the UNGC since 2005, and we have publicly reported annually regarding our Communication on Progress. The UNGC has never made any statement, assessment or inference that Barrick, or any of its subsidiaries, are in any way not conforming with the UNGC’s Principles or the Communication on Progress.

Upon request from certain shareholders, we have described below Barrick’s engagement with MSCI, MSCI’s assessments of what it terms as ‘Very Severe’ Controversies pertaining to mines that are owned and operated by affiliates of Barrick, and Barrick’s positions concerning MSCI’s statements with respect to alleged failures to align with the UNGC.

Our concerns are based on two topics: 1) engagement, and 2) assessment of controversies. 
 

1. Engagement and Responsiveness

Barrick had raised a number of concerns regarding MSCI’s assessment of longstanding alleged “controversies” concerning certain of the mines owned and operated by affiliates of the company, particularly those assessed as ‘Very Severe’. Among other things, we have communicated our concerns that MSCI does not appear to have considered information submitted by Barrick, and had not explained why. MSCI has reiterated that all Barrick submissions are, and will continue to be, considered in its assessments even if MSCI does not acknowledge those submissions or provide feedback.

MSCI and Barrick’s then CEOs held a meeting in December 2021, and agreed a path forward for future engagement. These engagements did not transpire in the subsequent years, however a number of engagements have been held between Barrick and MSCI since October 2025 and lines of communication have been clarified. Although Barrick and MSCI disagree on the level of engagement, or lack thereof, that has occurred in the past, resolution on the relationship going forward has been achieved.

Barrick has also offered to participate in additional calls with MSCI to provide detailed feedback regarding alleged “controversies” and MSCI’s application of their methodology to such cases (see North Mara below). MSCI has requested for Barrick to use MSCI’s online platform and inbox to submit feedback.  Of course, the offer for a call remains open to MSCI and will continue to be pursued by Barrick.

The ability to provide important context to MSCI is not only important for our business, but we resolutely believe this will enhance MSCI’s analysis and product. This has become an increasing theme expressed by current and prospective Barrick investors during our engagements with them, particularly in the last 18 months. Some investors have raised specific queries with respect to MSCI’s analysis of Barrick.
  

2. Controversies 

We accept the role that “controversies” play in ESG Ratings Agencies’ identification of risks. However, Barrick has noticed a pattern in the assessment of controversies and the inconsistent application of MSCI’s own methodology. This is of concern to us and is a topic of frequent discussion with our investors. We believe more transparency from MSCI is a necessity to establish trust among all parties.

We detail our concerns with respect to MSCI’s assessment of “controversies” under the various headings below. All this feedback has been shared directly with MSCI.

 
2.1  MSCI Methodology

Under MSCI’s “controversy” case assessment overview, MSCI states that controversies arise when reported negative impacts are allegedly caused, contributed to or linked to a company’s operations, or when the company is allegedly involved in misconduct that enables adverse impacts.

MSCI goes on to explain that its ESG Research ‘does not act in a journalistic or investigative capacity’, nor ‘does it fact-check or evaluate the merit or validity of any information in the sources cited’ by MSCI. It is unclear how any information that remains unvetted, unvalidated, not fact checked and uninvestigated can be a proper source from which MSCI seeks to ‘identify controversy cases, assess the severity of allegation or evaluate the company’s involvement’. This is compounded by MSCI’s unilateral assessment of a company’s compliance with Global Norms, such as the UNGC, which is addressed further below.

Despite MSCI’s position of remaining objective and not validating or vetting any information, it is evident that MSCI prioritizes NGO allegations above any facts provided by Barrick. Our experience is that Barrick’s information does not seem to hold the same weight as information provided by external sources, even when the information provided by external sources is unverified. This has been exacerbated by MSCI’s change to the Company Response section (in August 2024) in which we are given an opportunity to provide a single link to a controversy response. Any summary or review of company disclosures or third-party information is excluded from the controversies analysis and reduced to this single link hosted elsewhere.

It is stark that unvetted information from NGO allegations are included in MSCI’s assessment, along with MSCI’s assessment of supposed complicity (reached without conducting any investigation), while any company response or third-party specialist reports are excluded from the assessment under the guise of objectivity.

We must ask why NGO input is being incorporated as fact, but Barrick’s disclosures continue to receive little to no consideration?

We raise this as an increasing concern, in that MSCI’s research seems to be headline-focused, but unfortunately does not include  any due diligence. Our experience on the ground – which is the context we have been so eager to share with MSCI – is there are many organizations that make unsubstantiated claims that are simply seeking financial gain from the allegations, and MSCI’s lack of due diligence is perpetuating their ill-intended objectives.

Given MSCI’s in-house expertise in assessing a company’s approach to risks and management thereof, including with respect to human rights and community, Barrick expects MSCI to conduct due diligence before amplifying individuals or organizations whose allegations have no basis in fact or evidence and who do not have the consent of the communities to represent them or speak on their behalf.

We are concerned that MSCI’s recent decision to expand its ‘assessment’ of controversies to include other Global Norms, such as the International Labor Organization (ILO) standards and UN Global Principles on Business and Human Rights (UNGPs), will exacerbate these issues if the flaws in its current methodology and application are not first resolved. We have also expressed concern that the language MSCI uses in their ESG Controversy Reports is inconsistent with the language they use in their methodology documents. That is, the ESG Controversy Reports indicate whether there has been a ‘Fail’ or ‘Pass’ in relation to a Global Norm, however MSCI’s methodology documents ( reiterated to Barrick in email) state that they are merely passing judgement on ‘potential misalignment’ with Global Norms. This inconsistency in language is misleading and damaging to companies’ reputations.

 
2.2 ‘Very Severe’ Assessments and ‘Engagement Points’

MSCI has assessed Barrick as being involved in two controversies of ‘Very Severe’ status. The ‘Very Severe’ controversies are also deemed to be an UNGC ‘failure’ according to MSCI Controversy Reports. UNGC failure is seemingly based on the subjective assessment of UNGC Principles 1 and 2: respect for Human Rights and ensuring that a business is not complicit in human rights abuses. The UNGC makes it clear that risk of complicity exists in every sector and every country, but complicity is mitigated (although never eliminated) through the systematic management approach that a company applies in meeting its obligations to respect human rights (as per Principle 1 and the UNGPs).

MCSI’s assessment of an UNGC ‘failure’ does not determine complicity, and does not acknowledge the policies, procedures, standards and human rights program implemented by Barrick, as well as the new management team and sustainability strategy implemented since Barrick’s merger with Randgold Resources Limited in 2019.

This is most troubling, as MSCI are effectively making a unilateral judgment of ‘complicity’, based on allegations and information that remains unvetted and uninvestigated, all without performing any meaningful analysis and undertaking an objective review of Barrick’s information. Context is ignored, due diligence is not conducted and there is no consideration of disclosures made by Barrick or information provided by independent third parties. This is problematic for many of our shareholders who are aware of MCSI’s reports of UNGC failure but cannot decipher how this assessment has been reached or how we are implementing measures to address such risks.

The reality is simple and straightforward: Barrick has not been complicit in any human rights abuses.

By way of example, we detail below inconsistencies in these two ‘Very Severe’ controversies and MSCI’s ‘Engagement Points’ – the latter being the upgrade conditions set by MSCI and subsequently removed from their ESG Controversies Report.Removed in October 2025 after the publication of this disclosure.

 
2.2.1 North Mara, Tanzania, Human Rights Concerns

Several allegations have been made by international NGOs against North Mara for more than a decade, the majority of which  relate to the pre-2019 period and before  Barrick acquired the remaining equity in Acacia. Barrick has made many public disclosures on North Mara, which do not need to be repeated here. However, we wanted to highlight the extent of these disclosures that remain mostly disregarded in MSCI’s assessment, and identify significant problems with MSCI’s assessment:

• All the allegations are concerning the conduct of the Tanzanian Police Force. No allegations have been made against private security contractors or employees of the Tanzanian company that owns and operates the Mine. Barrick does not, and cannot be expected to, direct, supervise or control a national police force which is mandated to uphold law and order under the constitution of Tanzania. Based on MSCI’s methodology associated with Company Role, ‘indirect’ assertions are made when ‘the alleged negative… impact has been linked to the company through … government relationships’. By contrast, ‘direct’ assertations are based on misconduct alleged from company ‘employees, management or other representatives’. The Tanzanian Police Force cannot, in any capacity, be considered a company representative, nor are they present solely due to the company’s presence in North Mara. Based on MSCI’s own methodology, and even ignoring the points to follow, this controversy is ‘indirect’ (Exhibit 2), and based on its conclusion status (Exhibit 10) cannot be considered a UNGC failure or ‘Watch List’. MSCI has failed to apply its own methodology in this instance, and has not explained how Barrick has a direct role in allegations made against a sovereign police force.

• Notwithstanding the incorrect application of MSCI’s own methodology, we remain committed to engaging transparently. Supporting documentation provided to MSCI includes:
• Materials prepared in connection with site visit hosted for the UK NGO RAID.
• A formal response to the UN Human Rights Council addressing misinformed allegations. The UNHRC has not submitted any further information or disputed any statements in our response.
• An independent field visit and public statement undertaken by the International Code of Conduct Association (ICoCA) to review allegations against North Mara’s private security contractor, SGA. ICoCA concluded that, among other thing, the ‘Police are controlled through their own hierarchy in what appears to be clear demarcation of command and control’ and ‘No credible evidence was found implicating SGA in human rights abuses’.  
• Dismissal of legal cases by the Ontario courts on jurisdictional grounds.
• Engagement with the Tanzanian Human Rights Commission which, following investigation, found no evidence of forced evictions and nothing to substantiate allegations made by the NGOs included in MSCI’s controversy report.
• In addition, an independent third-party assessment was conducted by Synergy Global between 2019 and 2022, commissioned by MMTC-PAMP, one of our gold refiners.  The executive summary of this report is publicly available.

Although MSCI has since removed its list of Engagement Points, it is important to note that Barrick provided MSCI with information in connection with matters that MCSI itself had listed as upgrade conditions. MSCI’s list of unilateral Engagement Points (upgrade conditions) stated that upgrade of the controversy is possible when the following conditions have been met:

• The company has addressed long-standing community concerns regarding persistent poverty and unemployment, by providing alternative sources of livelihood to residents, such as opening adequate safe and secure artisanal mines to the community.
• The company has addressed complaints that displaced residents were given inadequate compensation by the Tanzanian government for lands acquired by the company to develop the North Mara mine.
• The company has made significant progress in implementing its commitment to provide education and health services, as well as transportation and water infrastructure benefiting the seven host communities surrounding the North Mara mine.
• An independent third party has recognized a sustained, peaceful relationship between the company and the local host communities.

North Mara has seen significant population growth in the eleven surrounding villages since the early 2000s, with the most recent estimates being 120,000 people. A 2022 Socio-economic Impact Assessment estimated that approximately 25% of the residents in the surrounding villages are migrants. Contrary to the implication of the Engagement Points, the two predominant reasons for this influx are job opportunities and security – that is, the area of the North Mara Gold Mine is viewed as safer and more secure compared to surrounding areas.

Engagement Points 1 and 3 above are troublesome in that MSCI has seemingly applied quasi-governmental responsibilities to a private enterprise: that is, the expectation appears to be to remove poverty and make progress in education, health, water and transportation for an ever growing population that has increased by more than 50% over the span of 10 years. These recommendations fail to acknowledge the role of the State and disregard the UN Guiding Principles on Business and Human Rights (UNGPs).

Barrick’s approach to sustainability is rooted in ensuring that communities benefit from the operation of mines owned by our affiliates. Our sustainability-related interventions have focused on many of these aspects, which are seemingly disregarded by MSCI:

• 97% of employees at North Mara are Tanzanian nationals, and nearly 60% are drawn from the local community, more than a 25% increase since 2019.
• Local and regional procurement has seen the supplier base grow by over 200% since 2019. In 2024 alone, some $135m was spent on these suppliers.
• Community development investment is directed by Community Development Committees (CDCs). In other words, this is community-led decision making. These investments have included:
• Revitalizing local healthcare facilities with improved infrastructure by building and renovating classrooms, teachers’ housing, paediatric and maternal wards, laboratories, pharmacy buildings and more.
• Supporting 21 business groups in Tarime with seed money through the Matongo Agribusiness incubator program that provides livelihood opportunities. The project now provides direct jobs and horticultural training and technical skills to over 50 youths and 300 women in the local area.
• Partnering with the Rural Water Supply and Sanitation Agency (RUWASA) in Tarime to rebuild the 300,000-liter Tailings Storage Facility at North Mara to provide reliable, potable water to over 35,000 people in the four surrounding villages, with plans to extend the project to another seven villages in the area.
• In addition to the CDC investments, the following significant investment commitments have also been made:
• Committing $30 million to funding local education, including sponsoring the construction of 1,090 seminar rooms and 1,640 ablution blocks at Tanzanian schools.
• Constructing nearly 3 kms of easily accessible tarmac road, linking four neighbouring villages together, with a future $40 million commitment dedicated to improving the road between Kahama and Kakola.
• Delivering comprehensive Human Rights and Gender-Based Violence Community Awareness training, all aligning with international standards and obligations.

North Mara has clearly met some of the immeasurable ‘conditions’ set by MSCI.

Our greatest concern with respect to MSCI’s upgrade conditions is the reference to ‘opening adequate safe and secure artisanal mines to the community’. This concept appears to have been drawn from statements made by international NGOs. This is an entirely unacceptable condition that misunderstands the situation in the area of the North Mara Gold Mine. We have publicly explained the problems associated with such an expectation, namely:

• Artisanal and Small Scale (ASM) licenses do exist in the North Mara region. These are permitted and regulated. The challenges faced by North Mara are not from ASM, but rather illegal miners – who do not have permits, do not comply with regulations and knowingly and illegally trespass into North Mara’s private property to steal, and who use gold as part of broader illicit activities and smuggling.
• Illegal mining groups, backed by criminal syndicates, use child labor and likely forced labor. In addition, these groups implement limited if any environmental controls, resulting in chemicals and waste effluent flowing freely into the environment, including the Tigithe and Mara rivers upon which the community relies.
• Ensuring that artisanal mines run by the community are safe and secure is not the responsibility of a private enterprise.

Engagement Point 2 is without merit and is not linked to the Controversy in any capacity.

MSCI’s final condition, Engagement Point 4, indicated that an upgrade could occur when ‘An independent third party has recognized a sustained, peaceful relationship between the company and the local host communities.’ This language is concerning to us, because it suggests that independent assessments conducted by professionals with substantial expertise are disregarded in favour of unsubstantiated allegations made by agenda-driven NGOs, simply because professionals with substantial expertise are generally compensated for their work.

Most concerning for us, however, is that this statement is also in direct contrast to independent and third-party studies undertaken at North Mara. As noted above, between 2019 and 2022, the refiner MMTC PAMP commissioned a human rights assessment by a firm called Synergy. The Synergy report, which highlighted significant measurable improvement, was independent and prepared by a third party, so it is again unclear how MSCI has assigned and weighted opinion in their analysis and discounted this report whose executive summary was made public on a third-party website.

UPDATE: Since our engagement in October 2025, the assessment of this controversy was upgraded from a ‘0’ Red Flag to a ‘1’ Orange Flag. However, our concerns expressed above, notably with the application of MSCI’s own methodology and with faulting Barrick for the alleged conduct of an independent police force, remain valid.

 
2.2.2 Porgera, Papua New Guinea, Human Rights Concerns

The last example we wish to raise of particular concern is the MSCI finding of UNGC failure at Porgera. This is an operation that has a difficult past which we have fully disclosed, regarding human rights violations that occurred in the 2000s. We responded with immediate and thorough action, conducting internal inquiries and commissioning an independent investigation.  As a result of this process, several employees were dismissed for their involvement in, or failure to report, incidents of sexual violence.

Alongside cooperating fully with the police, we engaged with stakeholders to develop the Porgera Remedy Framework, a comprehensive and, importantly, independent program to provide remedy to survivors of sexual violence.  Launched in 2012, the framework followed 18 months of consultation with national and international human rights experts and was one of the first processes established under the UN Guiding Principles on Business and Human Rights’ “Protect, Respect and Remedy” framework.

The remedy process remained open for more than two years and was independently administered.  It concluded in 2015, with 119 claims resolved through the framework and a further 15 addressed separately. No further credible allegations have been received since 2015. 

MSCI listed the following Engagement Points as conditions to upgrade the controversy:

• The mine owners have resolved all compensation claims related to rape, sexual assault, and other forms of violence against local residents.
• The company takes concrete measures to provide assistance to the affected community and improve the safety of the communities impacted by its operations.
• An independent third party has recognized a sustained, peaceful relationship between the mine owners and the local host communities.

As explained above, Engagement Point 1 has been completed through the independent Porgera Remedy Framework (PRF) and Barrick considers this matter closed. It has been 10 years since remedy was provided. MSCI continues to list allegations of ‘inadequate’ compensation made by self-declared ‘representative organizations’ (without evidence that they represent any victims) to justify MSCI’s decision not to close this controversy, but ignores that the PRF was an independent process including the determination of remedy.

Engagement Point 2, as highlighted above, is entirely immeasurable and it is unclear what ‘assistance’ MSCI refers to as being necessary, nor is there evidence to suggest there are safety concerns related to the operation of the mine. Engagement Point 3, as with the example of North Mara example, is seemingly ignored by MSCI in its assessment of Barrick.
  

Conclusion

Barrick continues to be a proud signatory of the UNGC, and we have publicly reported annually regarding our Communication on Progress, including an annual commitment that we are steadfastly committed to the principles of the UNGC. The UNGC has never made any statement, nor reached any assessment or published any inference, that Barrick or any of its affiliates are in any way not conforming to the UNGC’s Principles or the Communication on Progress.

Barrick has remained committed to engaging with all its stakeholders and engaging in a transparent and open manner. This engagement has included third-party data analysts, including MSCI. Barrick has been informed that the “failure” assessment will be maintained by MSCI until such a point in time where no public reference of the ‘controversy’ is made over a 3-year period. That is so even though public ‘references’ are not vetted and apparently MSCI does not require that their veracity be demonstrated. This arbitrary and highly unlikely condition is not tethered to reality and encourages a culture of ‘paying to get rid of a problem’, thereby creating an exploitative environment by signalling that people who make unsubstantiated allegations will be rewarded.

In addition, MSCI has informed us that the appropriate language associated with UNGC and other Global Norms should be interpreted as ‘Potential Misalignment’ as outlined in their methodology report (page 22) and not as a ‘Failure’ as per the language used in the ESG Controversies Report. Barrick has expressed its concern at the inconsistent use of language between their reports and strongly recommended correction to ensure transparency in this regard.

Barrick will continue to engage with the analysts and to ensure that they have the correct information, while calling on them to make their own assessments and methodology more transparent. Barrick is also committed to engaging with our shareholders to enable them to make their own assessments and informed decisions about our company and not have to rely solely on third party analysts that prioritise complete risk aversion as their core business product.