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Sustainability > Our Approach

Ethical Business Conduct

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

Code of Business Conduct and Ethics

Not only is corruption contrary to our values of integrity and responsibility, it also erodes the social fabric of the communities where we operate.  With thousands of Barrick people, suppliers, and contractors, working in highly diverse countries, the possibility of our exposure to potential incidents of bribery and corruption is real.

We have a Code of Business Conduct and Ethics, that identifies our obligations, as a company and as individuals, directors, officers, contractors, or third-party vendors to comply with all applicable laws and to avoid and report bribery and corruption wherever we work. It sets forth core principles that govern our work, and identifies the many resources available to help our people and contractors understand how these principles relate to their jobs.

To communicate our high expectations of ethical behavior as clearly as possible, Barrick provides mandatory training on the Code to all new people working for Barrick. In addition, all people in administrative offices, and supervisors or above at mine or project sites, are required to undertake annual refresher training on the Code. In total, over 5,800 people at Barrick received focused anti-corruption training in 2017.

Barrick expects all of its people 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 people raised concerns about potential violations of the Code either through local channels or through our formal reporting channels, including the confidential hotline.

Code of Conduct Cases Received in 2017

In the past year, our people 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 Received During 2017 by Country and Type

Code Of Conduct Cases Received During 2017 By Type

Anti-Corruption Compliance Program

Anti-Corruption Policy

Barrick has a global Anti-Corruption Policy and an Anti-Corruption Compliance Program that helps our efforts in seeking to 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.

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.

As part of the program, Barrick has developed detailed procedures for government agreements, government support, and other transactions, including political donations, charitable contributions, government-related direct and in-kind support, per diems, meals, gifts, entertainment, and travel. Charitable contributions are also subject to enhanced processes. We have also introduced guidance materials in key areas (including risk assessments, invoice red flags, onboarding and monitoring intermediaries, asset acquisitions and joint ventures, and government-related support).

We conduct risk assessments as well as systems and process testing of all (100%) of Barrick sites for risks related to corruption. This includes periodic in-depth site-level assessments for medium- and high-risk sites. In 2017, the Company completed desktop anti-corruption self-assessments in Chile, the Dominican Republic, and Peru, as well as live site-level assessments in Argentina and Zambia.  The Porgera Joint Venture also conducted its own independent self-assessment.  These and other assessments identified areas where communication between functional units and compliance can be strengthened.

Transparency

Barrick believes that transparency and reporting can be powerful tools against corruption.

 

We also conduct due-diligence when entering into joint ventures or undertaking acquisitions.

As part of our program, the Company sets internal Key Performance Indicators related to anti-corruption. In 2017, these included:

  • Focused training and education activities: Of relevant people, identified on a risk-tiered basis, 98% received live anti-corruption training. The Audit Committee of the Board also received updated anti-corruption training. In total, more than 2,200 people received live anti-corruption training and an additional 3,650 people received online training.
  • Due diligence of Barrick people and relevant vendors: By the end of 2017, over 99% of mining operations third-party vendors (more than 10,600 vendors) had been onboarded as per the Vendor Onboarding Standard, which included at least baseline anti-corruption due diligence.
  • Scrutiny of government intermediaries and agents: over 99% of new intermediaries and government-affiliated vendors received enhanced due diligence in 2017. Out of 178 government affiliated vendors, only one had not yet received due diligence by the end of 2017.
  • Frequent communications from Company leaders: More than 30 ethics messages from senior corporate and site leaders were delivered to our people in 2017. In “effectiveness” testing through Sarbanes-Oxley scores, 99% percent of people confirmed basic knowledge of our anti-corruption policy.
Partnering Against Corruption

Barrick participates in a number of multi-stakeholder groups related to anti-corruption, including 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, acted as a Subject Matter Expert for the Canadian Centre on Anti-Corruption, and actively participated in additional panels and conferences.

 

Barrick expects all its people 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 concerns to be raised properly;
  • Includes internal procedures surrounding investigations of potential Code violations and reporting to appropriate levels of management and the Audit Committee of the Board as appropriate; and
  • 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 termination of our people or third parties involved in unethical business conduct.