Code of Conduct PT Newmont Mining Corporation

Our Code of Business Ethics and Conduct ("Code") reaffirms the high standards of ethical business conduct required of all Newmont employees, officers and directors. Our Code has been adopted by Newmont's board of directors and constitutes Newmont's basic standards of ethical and legal behavior. Our Code supersedes the company's previous code of ethics and conduct.Acting with integrity, trust, respect, honesty and teamwork - all stated values of Newmont are principal characteristics of ethical behavior. For all of us, the basic requirement is that we conduct ourselves in a responsible manner, putting the company first in all our work-related decisions. While there is no substitute for common sense, our Code has been created to provide guidance to employees, officers and directors of Newmont on how to conduct the company's business, and to help identify critical issues that require caution and both ethical and legal consideration.Our Code also has been created as an educational and preventive tool - in part, designed to help prevent and detect violations of the law. In most circumstances, however, Newmont's standards are higher than the law requires. These expectations are further defined and more guidance is provided through our policies. Newmont has policies in most areas touched on in our Code including, but not limited to, workplace conduct and safety, securities trading, environmental protection, social responsibility and anticorruption measures. Adherence to these policies and our Code preserves the

we live our values by being responsible and accountable for our actions. performance appraisals for all personnel include an evaluation of their demonstration of ethical behavior in compliance with our Code. regardless of position or status. In addition. to address all applicable laws or policies. however. accountable for complying with Newmont's Code. Each of us also is obligated to comply with all other applicable laws. that our Code is not intended to provide specific answers to unique legal questions. it is your responsibility to ask a manager. or to set standards of conduct enforceable against Newmont. We are responsible for knowing and complying with the laws and policies that relate to our duties.confidence and support of the public and Newmont's stockholders. All employees are accountable for reviewing our Code and certifying annually that they have done so.It is important to note. to set forth a rule for every situation. policies. or contact the legal department or the compliance line to get clarification. If you do not understand our Code. licensing agency or professional association governing our professional activities. to create legal rights or duties. up to and including termination of . Our Responsibilities At Newmont. officer and director. applicable laws or Newmont's expectations for your behavior. Failure to live up to the responsibilities in our Code may result in disciplinary action being taken. and all local and national laws in all countries in which we do business. a policy. rules and regulations of any regulatory organization. Accountability Newmont holds each employee.

You also can contact the legal department or the internal audit department directly. and other criminal or civil sanctions. Additionally. . or will be able to refer your question to another appropriate source. Another communication channel available to assist you is the compliance line. violations may subject involved individuals and Newmont to criminal and civil penalties. including a manager in the human resources department. honest and constructive two-way communications with them. Managers must assist in preventing violations of our Code. This means not only allowing. managers are expected to lead by example. as well as someone from a department who has the expertise and responsibility to address the concern. You can contact the compliance line anonymously. including fines. managers must escalate reports of alleged violations for investigation and cooperate with all investigatory actions. or talk to someone else in management. The compliance line. When allegations of wrongdoing are brought to their attention. Any of these people may have the information needed. you can speak with your direct manager or supervisor. jail sentences. but also encouraging employees to ask questions. Additionally. You can contact the compliance line when you have a concern or want to report a potential violation of our legal or ethical responsibilities. Each manager should discuss Newmont's expectations for ethical conduct with his or her direct reports during the annual performance review process. Managers must show respect toward employees and maintain open. Managers must communicate our Code and relevant Newmont policies to their direct reports and help them understand these requirements. make suggestions and report concerns or wrongdoing. is available to all employees. which is answered by a third-party vendor who is not an employee and does not office on any of our sites. as well as any resulting corrective or disciplinary action Ways to Ask Questions and Voice Concerns When you have a question or concern. because many provisions of our Code and Newmont's policies are based on legal requirements.employment. Newmont's policies and the law.

to report what is known and to get questions answered. you can expect that: * If you called the compliance line.24 hours a day. or be retaliated against in any way for asking questions or voicing concerns about our legal or ethical obligations when acting in good faith. "Good faith" does not mean an individual has to be right. If you become aware of a situation in which you believe legal or ethical responsibilities are being violated. you should bring these to your manager's or the legal department's attention. The compliance line is not equipped with caller ID or other devices that can identify or trace the caller's number. Interpreters are available for language assistance. 7 days a week. Asking Questions and Voicing Concerns If any aspect of our Code is unclear. your call will be assigned a tracking number and a report will be forwarded to appropriate management for follow-up. The important thing is to get the needed guidance. or if you feel that you are being pressured to violate the law or your ethical responsibilities. * Regardless of how you raise it.You may use whatever method of communication is comfortable for you. A Newmont employee will not be on your call. Discussions and inquiries will be kept in confidence to the extent appropriate or permitted by law. your concern will be handled discreetly and professionally. or if you have any questions or face dilemmas that is not addressed in our Code. it is your personal responsibility to communicate this concern to management or the legal department. After a Concern is Raised When you raise a concern.No employee will be disciplined. but it does mean the employee has to believe that the information provided is truthful. Your concern will be addressed by members of . you can obtain follow-up information about the status of your report and how the concern was addressed. lose a job. By calling back the compliance line and providing the tracking number.

could subject both the individual offender and Newmont to legal liability. confidentially. * Investigations into allegations of unethical or illegal conduct will be conducted professionally and to the extent possible. which may include representatives from the legal department or the internal audit department.If you suspect that you. has been retaliated against for raising a Code compliance issue. Our Commitment to Each Other .Retaliation will not be tolerated at Newmont. and as such. Retaliation also may be a violation of the law. up to and including termination of employment. Failure to cooperate in any such investigation shall be grounds for discipline. you should immediately report such allegation to the legal department or via the compliance line.management. up to and including termination of employment. Each concern will be carefully evaluated before it is referred for investigation or resolution. All of us must cooperate in such investigations. it will be referred there for resolution. If the inquiry is one that can be properly handled by someone in the region. or someone you know. No one should be discouraged from using any available channel within the company. People must be able to choose whichever method they are most comfortable with to communicate their concern. Anyone who retaliates against another employee for reporting known or suspected violations of legal or ethical obligations is in violation of our Code and subject to disciplinary action. Protection Against Retaliation We have a responsibility to foster an environment that allows people to report violations or suspected violations without fear of retaliation or retribution.

national origin. all as defined by the applicable law for each global work site. We further strive to recognize and reward creativity. We strive to provide a work environment in which we all are encouraged to share information. These laws and site-specific policies will provide more details on how we are to conduct ourselves. merit and other work-related criteria. sex.We recognize that our people are our most important asset and our performance as a company depends on respect for people. Please refer to those policies for more detail on the topic. place. We consider workplace accommodations as appropriate to comply with all applicable laws governing fair employment and labor practices. Equal Opportunity We recruit. It also is important that we review and comply with the employment policies in place at a particular site. disability and age. There are more specific equal employment policies at each site.Numerous laws and policies affect our work force. sexual orientation. As one of our values. we are committed to developing our people in the pursuit of excellence. take an active part in reaching our strategic goals and feel a sense of pride in working at Newmont. religion. including experience. as well as harassment in violation of site-specific . and we will treat each other with respect and dignity.Our work force is dynamic and diverse. select. It is important that we comply with all applicable employment and labor laws within each country where Newmont operates. race. promote and compensate employees on the basis of their qualifications for the work to be performed. and what follows are some of the conduct standards. We recognize that our people are our most important asset and our performance as a company depends on respect for people. Anti-Harassment Our work environment will be free of illegal harassment based upon legally protected categories. a determination to excel and a commitment to action. work as a team. but not limited to. We also support and obey laws everywhere we do business that prohibit discrimination on the basis of legally protected categories including.

Please refer to site-specific policies for more detail to prohibit harassment. Newmont or others in harm's way.Further. • Veiled threats of physical harm or similar intimidation. we do not tolerate workplace violence of any kind. as required by law. • Any conduct resulting in an arrest or conviction under any criminal law relating to violence or threats of violence. associates or property. regulations and policies for the facility where we work. Newmont prohibits any act or threat of physical violence while conducting Newmont business. We shall identify potential risks before accidents occur and integrate our safety management systems into the way we do business. We must promptly report accidents and dangerous situations to our managers or the human resources department. as well as any and all applicable government agencies. it will not be done at all. We will . • Stalking. Examples of conduct that may constitute threats or acts of violence under our Code include: • Threats or acts of physical or aggressive contact directed toward another individual or his or her family. or threat of the defacing or destruction of Newmont property or another employee's property. defacing of. If you observe conduct that runs contrary to this principle. • The intentional destruction. Prohibited Activities We do not tolerate illegal activity while on Newmont premises or while on Newmont business as it could put you. you have a responsibility to notify the human resources department or contact the compliance line. friends. while on Newmont property. vendors or contractors. If a task cannot be done safely. • Harassing or threatening phone calls or e-mails. Workplace Safety We must use common sense and follow applicable safety laws. or while interacting with any Newmont employees. We must take the necessary precautions to prevent occupational illness or injuries.harassment policies. We are committed to working toward an injury-free workplace.

in Newmont vehicles or on company business: • Consumption and storage of alcoholic beverages at an operations or technical site. Specifically. transfer.comply with all laws and company policies. you must immediately report to your manager any on-the-job or off-the-job traffic ticket. Off-duty misconduct could jeopardize workplace safety or security. whether related to our Code or not. if you operate company motorized vehicles as part of your work assignments or are covered by a transportation authority's regulatory requirements. If. while on Newmont premises or while on Newmont business. such as illegal drugs. distribution. except when authorized by a member of senior management of the company and otherwise legally permitted. you have additional reporting requirements. we have an obligation to let Newmont know of our own off-duty misconduct as well as the off-duty misconduct of other employees. • Driving vehicles or operating company equipment while under the influence of alcohol or controlled substances. except by security or other personnel who are authorized by Newmont. you are engaging in activities contrary to law or policy. Off-Duty Misconduct Our conduct that occurs away from Newmont property and outside of the normal course of Newmont business may also impact our company. Newmont's image and reputation. you will be subject to disciplinary action. • Illegal betting or gambling. purchase or usage of a controlled substance. • The possession of weapons of any sort. up to and including termination of employment. Thus. dispensation. possession. • The unlawful manufacture. . or our ability to carry out our duties. The following illustrates activities that are against company policy and that will not be tolerated while you are on Newmont premises.In the event you are charged with or convicted of a crime.In addition. sale. you must report that fact to your manager and to the human resources department within five days of being charged or convicted.

up to and including termination of employment. Our Commitment to the Company We recognize the trust and confidence placed in us by Newmont and must act with integrity and honesty in all situations to preserve that trust and confidence. up to and including termination of employment. is also prohibited. including trespass on lands owned by others or the offering of bribes. misrepresentation of material facts or any other similar practice. Any use of fraudulent or illegal tactics. at our sole discretion and in accordance with applicable law. Newmont may.The impact of any off-duty misconduct on Newmont's interests will be assessed on a case-by-case basis. take disciplinary action. Communications We will communicate with each other in a respectful. honest and transparent manner in accordance with our values. abuse of privileged information. fictitious or fraudulent information. Participation in any such activity will subject you to discipline. Fraudulent or Dishonest Conduct Under no circumstances will we offer any false. or take unfair advantage of anyone through inappropriate manipulation. We will comply with our legal . report or claim to another person. concealment. citation or other issue that impacts the status of your driver's license. and all such activity must be reported to the legal department or the internal audit department.accident.

suppliers and other stakeholders informed on a timely basis through regular public releases of relevant and understandable financial and other information about Newmont. you must be an officer of the Newmont entity that is a party to that contract or agreement or hold a written power of attorney from an officer. malicious or defamatory of any other person or company is prohibited. use and disclose employee information on a business need-to-know basis in conformance with applicable regulations or when required by law or court order. either internally or externally. other policies with regard to communications. (Typically. Auditors’ Independence On a regular basis. from time to time. Most of these limitations are either limitations on binding the company or limitations on spending company funds.obligations to keep shareholders. Newmont is committed to treating personnel records and medical files with the same respect and confidentiality given to the company's records.Further. we must not execute any contract or agreement on behalf of Newmont unless we are authorized by law to do so. including the use of Newmont's electronic communications systems. .The publication or circulation. of any oral or written statement that is false. If you need to clarify yours or another individual's authority to sign contracts or agreements or to commit Newmont funds. we are expected to be familiar with and observe all such policies.) Also. you should contact the legal department. In short. We cannot take any action intended to improperly influence Newmont's auditors or the conduct of their audits.Newmont has issued and will issue. we must not approve transactions or make commitments for Newmont funds unless the dollar amounts we are committing are within our authorized approval level. Newmont will only collect. as specified in the executive authorities. officers and directors. This policy also applies to former employees' information. creditors. outside auditors will review Newmont's financial information. Authority to Act on Newmont’s Behalf Everyone has limitations on what he or she can do on behalf of Newmont. securities trading markets.As employees.

the practice can create a conflict of interest or the appearance of impropriety. Newmont's business must be conducted solely for the best interests of the company. in certain circumstances. and when it is acceptable to receive a gift and when it is not acceptable. officers and directors. No employee.Our Relationships We will act responsibly. officer or director. This practice in a business context is typically meant to create goodwill and establish trust in business relationships. we must learn how to distinguish when to give and when not to give a gift. Gifts and Gratuities The giving and receiving of gifts and gratuities are commonplace in most societies. We must avoid conflicts of interest and other situations that are potentially harmful to Newmont when we deal with others. However. but not in Newmont's best interest . or a member of his or her family may. directly or indirectly. use his or her decisionmaking authority or position to receive any improper personal benefit from any sale. in accordance with our values and in a manner that will reflect favorably on us and Newmont. Thus. in an honest and ethical manner. we must avoid situations where Newmont's interests and our own self-interest are or appear to be inconsistent. purchase or other activity of Newmont or in a way that is in his or her own interest. Avoiding Conflicts of Interest As employees.

We work with the mining sector. we assure that we do so in a fair manner that promotes competition. Our goal is to engage with host communities and governments early in the development of a mine to begin to understand the respective community and share work with it to equitably manage the value created during the mine operation. Finally. Acting with integrity when engaging with host governments and communities will assure that we uphold our values.Our Commitment to Communities We strive to engage and consult with communities and governments that host our operations and other stakeholders with respect. transparency and in accordance with the law. governments and host communities to monitor and work to prevent corruption.We each have an obligation to the host communities in which we operate.We remain steadfast in our commitment to sustainable partnerships. we are active participants and supporters of the Partnering Against Corruption Initiative (PACI). Environmental and Social Responsibility Our strategy for managing the environmental and social aspects of our business focuses on the incorporation of environmental and social considerations into the full range of our operations' decision . We strive to be good stewards of the environment and socially responsible through our actions. We will comply with all laws relating to our business abroad. both at our operations around the world and through our corporate philanthropy program in Denver. Further. while competing in today's market.

we will fully comply with all applicable U. which prohibit or regulate contributions by companies to political parties or candidates. Assisting in the Fight Against Corruption Conduct that may be acceptable in the commercial business environment may not be acceptable in relations with government officials. entities. including the U. Competing in Today’s World Generally speaking.. Government officials play a special role in society. If you . it is our goal to take part in projects to further the development and welfare of the local community. exports and the conduct of business with non-U.S.Political Contributions and Activities Many countries have laws. Your good judgment must always be your guide. the antitrust and competition laws of the United States and other countries forbid agreements or activities that restrain trade or limit competition and prohibit attempts to mon Conclusion While our Code sets forth the minimum standards of acceptable behavior.S. it is not intended to cover every issue that may arise.S. Our Code is not solely what we may and may not do. both nationally and in each state. Complying with International Trade Laws In conducting our business. Charitable Contributions Throughout the world. it also is about providing us with resources to support us in doing the right thing. laws governing imports.

Our Code is not solely what we may and may not do. contact the compliance line. contact the compliance line. it also is about providing us with resources to support us in doing the right thing. it is not intended to cover every issue that may arise. would my actions have the appearance of impropriety? . policies or procedures that address this situation? What about the "spirit" of the law? • Am I looking at this situation objectively or am I so emotionally involved that I should get help? • What are the motivations of the others involved? • How would I feel if my decision were featured on the front page of the newspaper? • If made public. need to report a situation or need support in doing the right thing. the first person you should turn to is your manager. If you do not feel comfortable doing so. regulations. When things are "grey. the legal department or another appropriate resource listed in our Code. it can be extremely difficult to know what to do. If you need help deciding how to handle a particular situation at work.need help deciding how to handle a particular situation at work. in some circumstances." ask yourself: • Are there any laws. the legal department or another appropriate resource listed in our Code. It is not always easy to answer this question and. Your good judgment must always be your guide. If you do not feel comfortable doing so.While our Code sets forth the minimum standards of acceptable behavior. need to report a situation or need support in doing the right thing. the first person you should turn to is your manager.

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