In conducting our business, we will fully comply with all applicable U.S. laws governing imports, exports and the conduct of business with non-U.S. entities. We also will comply with all relevant non-U.S. laws and regulations governing these topics. These laws contain limitations on the types of products that may be imported into the United States and the manner of importation. They also prohibit the export of goods to, and most other transactions with, certain countries. Finally, they prohibit cooperation with or participation in foreign boycotts of countries that are not boycotted by the United States.
Here is a summary of the laws we must adhere to:
• Export Laws: Exports of equipment, technology, software and technical data are regulated by different countries, including the United States. Many people do not realize that carrying an item on a trip outside your home country constitutes an export that may require a license. Similarly, sharing certain information (i.e., technical data) with other individuals in foreign countries via e-mail or regular mail, disk, CD, DVD, flash drive and similar devices, or even by allowing foreigners to view the information on your computer, regardless of where the review occurs, may require a license, even if you are not intending to do anything more than have someone review the material and comment on it. Likewise, the shipment of Newmont equipment to a Newmont project outside of the country of origin may require a license. The broad scope of these regulations, and the fact that relatively low levels of technology, equipment, hardware, software and technical information are regulated, is often misunderstood. You should direct questions and requests for assistance in this area to the legal department.
• U.S. Embargoes/Trade Sanctions: From time to time the United States or another country may prohibit or restrict trade and other commercial dealings between its citizens (including companies) and certain other countries, including residents and citizens of those countries. Violations of the restrictions and prohibitions can result in the imposition of substantial fines or imprisonment for prosecuted violators. We must adhere to the letter and the spirit of these restrictions and prohibitions. You should direct questions and requests for assistance in this area to the legal department.
• Anti-boycott Laws: A boycott occurs when one person, group or country refuses to do business with certain other people or countries. As a U.S.-based company, we must comply with U.S. laws pertaining to boycotts. The U.S. anti-boycott laws and regulations prohibit or severely restrict the company, our subsidiaries and certain affiliates from participating in boycotts against countries friendly to the United States. Additionally, U.S. law prohibits compliance with requests for information or other actions that further such boycotts. U.S. law also requires us to report, in certain instances, both legal and illegal boycott requests to the U.S. government. Violations can result in criminal penalties, loss of tax benefits and loss of export privileges. Boycott-related requests are difficult to recognize and the regulations affecting the company's reporting obligations are not always easy to understand. Therefore, you should direct questions and requests for assistance in this area to the legal department.
• Anti-Terrorism and Anti-Money Laundering Laws: Newmont will not conduct business with parties who may be involved in or support terrorist activities. Similarly, we will not knowingly accept funds that are derived from unlawful sources or activities. We are committed to complying fully with all applicable anti-money laundering laws throughout the world. Money is "laundered" when it is taken from an illegal activity and run through a legal activity to conceal criminal activity associated with it, including crimes that generate it, such as terrorism, drug trafficking or illegal tax avoidance. You should direct questions and requests for assistance in this area to the legal department.
