Newmont holds each employee, officer and director, regardless of position or status, accountable for complying with Newmont's Code, policies, and all local and national laws in all countries in which we do business. Each of us also is obligated to comply with all other applicable laws, rules and regulations of any regulatory organization, licensing agency or professional association governing our professional activities. If you do not understand our Code, a policy, applicable laws or Newmont's expectations for your behavior, it is your responsibility to ask a manager, or contact the legal department or the compliance line to get clarification.
All employees are accountable for reviewing our Code and certifying annually that they have done so. In addition, performance appraisals for all personnel include an evaluation of their demonstration of ethical behavior in compliance with our Code. Failure to live up to the responsibilities in our Code may result in disciplinary action being taken, up to and including termination of employment. Additionally, because many provisions of our Code and Newmont's policies are based on legal requirements, violations may subject involved individuals and Newmont to criminal and civil penalties, including fines, jail sentences, and other criminal or civil sanctions.
Additionally, managers are expected to lead by example. Managers must communicate our Code and relevant Newmont policies to their direct reports and help them understand these requirements. Managers must show respect toward employees and maintain open, honest and constructive two-way communications with them. This means not only allowing, but also encouraging employees to ask questions, make suggestions and report concerns or wrongdoing. Each manager should discuss Newmont's expectations for ethical conduct with his or her direct reports during the annual performance review process.
Managers must assist in preventing violations of our Code, Newmont's policies and the law. When allegations of wrongdoing are brought to their attention, managers must escalate reports of alleged violations for investigation and cooperate with all investigatory actions, as well as any resulting corrective or disciplinary action.
At Newmont, we live our values by being responsible and accountable for our actions. We are responsible for knowing and complying with the laws and policies that relate to our duties.