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Ethical Business Conduct

With thousands of employees, suppliers, and contractors, working in highly diverse countries, the possibility of our exposure to potential incidents of bribery and corruption is real, which can present risks to companies like ours that operate around the globe.

Not only is corruption contrary to our values of integrity and responsibility, it also erodes the social fabric of the communities where we operate.

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.


We have a Code of Business Conduct and Ethics, which identifies our obligations, as a company and as individuals, directors, officers, employees, and contractors, to comply with all applicable laws and to avoid and report bribery and corruption wherever we work.

Barrick also has a global Anti-Corruption Policy and Compliance Program that helps our conduct 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.


  • In 2016, the Company met or exceeded internally set Key Performance Indicators (KPIs) related to anti-corruption. These included:
    • Tone from the Top: More than 450 ethics messages from senior corporate and site leaders were delivered to employees in 2016. In “effectiveness” testing through Sarbanes-Oxley scores, 98% percent of employees confirmed basic knowledge of our anti-corruption policy.
    • Anti-Corruption Live Training: 100% of relevant employees, identified on a risk-tiered basis, received live anti-corruption training. The Audit Committee of the Board also received updated anti-corruption training. In total, 1,400 employees received live anti-corruption training and an additional 3,000 employees received online training.
    • Vendor Onboarding: Over 95% of new mining operations third-party vendors (more than 1,100 vendors) were onboarded as per the Vendor Onboarding Standard, which included anti-corruption due diligence.
    • Intermediaries and Government-affiliated Vendors: Over 99% of new intermediaries and government-affiliated vendors identified (110 in total) received enhanced due diligence in 2016.
  • In 2017, the Code of Business Conduct and Ethics was revised and updated to make it less formal, more closely connected to our core values, and more user friendly by incorporating clear examples and a section of frequently asked questions.
  • Each year, Barrick conducts a global risk assessment of all of Barrick sites for risks related to corruption; we then conduct periodic in-depth site-level assessments for medium- and high-risk sites. In 2016, the Company completed anti-corruption self-assessments at Lumwana and Veladero. These and other assessments identified areas where communication between functional units and compliance can be strengthened.
  • Barrick continues to participate in a number of multi-stakeholder groups, 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. Collective action with industry peers, local governments, and civil society is an important way to make progress on challenging societal issues.
  • Code of Conduct Violations: Barrick expects employees and Board directors 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 employees raised concerns about potential violations of the Code either through local channels or through our formal reporting channels, including the confidential hot-line.
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  • Code of Conduct Training: To communicate our high expectations of ethical behavior as clearly as possible, Barrick continued to provide mandatory training on the Code to all new employees in 2016. In addition, all employees in administrative offices, and supervisors or above at mine or project sites, are required to undertake annual refresher training on the Code. In total, approximately 4,500 employees received focused anti-corruption training in 2016.

Anti-Corruption Compliance Program

Our comprehensive global Anti-Corruption Compliance Program helps us 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.

The program includes:

  • Detailed procedures governing government agreements, government support, and higher-risk transactions, including political donations, charitable contributions, and government-related direct and in-kind support, per diems, meals, gifts, entertainment, and travel;
  • Guidance materials in key areas (including risk assessments, invoice red flags, onboarding and monitoring intermediaries, asset acquisitions and joint ventures, and government-related support);
  • Focused training and education activities;
  • Due diligence of potential and actual employees and relevant vendors;
  • Scrutiny of government intermediaries and agents;
  • Treatment of charitable contributions as higher-risk payments subject to enhanced processes;
  • Frequent communications from Company leaders;
  • Risk assessments and systems and process testing, focusing on higher-risk geographies; and
  • Diligence associated with joint ventures and acquisitions.


Barrick expects all employees, officers, and directors 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 employee concerns to be raised properly;
  • Includes internal procedures surrounding potential Code violations 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 employees and third parties involved in unethical business conduct.



Barrick believes that revenue transparency and reporting on our relevant programs, whether through the Extractive Industries Transparency Initiative (EITI), the Extractive Sectors Transparency Measures Act (ESTMA) or the Global Reporting Initiative (GRI), can be a powerful tool against corruption and in support of ethical business conduct.

Barrick was the first Canadian mining company to be a signatory to EITI. Since 2006 we have voluntarily reported detailed country-by-country information, including environmental and social data and the taxes and royalties we have paid to governments around the world. We also participate in the annual CDP Climate Change and Water Disclosure process, providing investors and other interested stakeholders with information on our water and energy use and emission data.