Newmont Mining Corporation

Conducting business with government officials is not the same as conducting business with private parties. These transactions are covered by special legal rules. For example, we are prohibited from making any kind of payment in monies, goods or services that could be interpreted as influencing a government official in respect to Newmont business (see the Assisting in the Fight Against Corruption section, page 47). Gifts given in certain situations, under certain circumstances and at certain times could be interpreted as influencing a government official's decision regarding Newmont's business and must be avoided.

Giving gifts to government officials (and members of their families or close friends) is discouraged. No gift, no matter how small, may be given to a government official, his or her family members, or his or her close friends if it reasonably could be expected to affect the outcome of a business transaction, confer any other undue advantage on Newmont or otherwise create the appearance of impropriety.

Even if none of these factors is present, a gift may only be given to a government official, his or her family members, or his or her close friends if it is legal under local law, in accordance with local business custom, not excessive, infrequent and appropriate for the occasion.

Gift exchanges with government officials are extremely complicated and can only be made in strict accordance with the policies set forth in our International Anti-Corruption Compliance Manual. If you are in doubt whether a gift to a government official can be made, you should most likely refrain from making it. If you have questions, please contact the legal department prior to making or promising a gift to a government official.