Newmont Mining Corporation

A potential conflict of interest exists if you are an owner of or director in another company that has a business relationship with Newmont, or competes with Newmont. Being in this position could interfere with your ability to make judgments solely in Newmont's best interest. These situations must be approved by Newmont management prior to your involvement with them. Your manager can assist in seeking the necessary approval. If you are an officer or director, you should seek such approval from either the general counsel or the chief executive officer.

Some examples of situations where pre-approval must be sought include:

• Employment by another company while continuing to be an employee of Newmont: The other company may do business or desire to do business with Newmont, which could create a conflict, or your involvement may interfere with your ability to perform your Newmont responsibilities.

• Ownership of a part of another company or business that has interests adverse to Newmont's or an interest in Newmont: An ownership interest in a company adverse to Newmont may create a conflict in your ability to perform your Newmont responsibilities. Similarly, an ownership interest in a company that owns an interest in Newmont may cloud your judgment in performing your Newmont responsibilities.

• Close or family relationships with Newmont's competitors: Having a close friend or family member who is directly involved with a competitor may create a conflict of interest when you perform your Newmont responsibilities.

• Participation in a business transaction between Newmont and a company in which you or your family member or someone with whom you have a close relationship has an interest: Personal ties to a transaction can create a conflict of interest for individuals working on that transaction.