Newmont Mining Corporation

While our Code sets forth the minimum standards of acceptable behavior, it is not intended to cover every issue that may arise. Your good judgment must always be your guide. Our Code is not solely what we may and may not do, it also is about providing us with resources to support us in doing the right thing. If you need help deciding how to handle a particular situation at work, 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, contact the compliance line, the legal department or another appropriate resource listed in our Code.

It is not always easy to answer this question and, in some circumstances, it can be extremely difficult to know what to do. When things are "grey," ask yourself:

• Are there any laws, regulations, 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, would my actions have the appearance of impropriety?