Many countries have laws, including the U.S., both nationally and in each state, which prohibit or regulate contributions by companies to political parties or candidates. Further, political contributions made by a corporate organization such as ours, which is a U.S.-based company, could draw strong responses from citizens of other countries.
Accordingly, we shall not make political contributions, directly or indirectly, outside the U.S. without approval by the general counsel and chief executive officer. Within the U.S., we shall make political contributions only in accordance with all U.S. laws and regulations governing such contributions.
We shall make information concerning all political contributions publicly available.
Meeting with politicians, political candidates and officials of political parties, attending political events in the capacity of a Newmont employee or for the benefit of the company, and lobbying for the benefit of Newmont is permitted to the extent authorized by our company and allowed by applicable law. We must get approval from the government relations department before engaging in any lobbying activity (including grassroots activities) on behalf of Newmont, either directly or through a trade or professional association. Note that if our activity is not directly on Newmont's behalf, but an inference could be drawn that we are engaging in such activities for Newmont, approval is still required.
Newmont encourages you to participate in the political process; however, always keep in mind that the law requires your political activity to be an entirely personal matter. If you want to serve on a political campaign committee or campaign on behalf of a candidate or party and are part of the senior management team, please let your supervisor know before agreeing to do so.
Subject to applicable law, you may make direct contributions of your own money in your own name, either directly to candidates or to political action committees, but contributions are completely voluntary and not reimbursable. If you make such a contribution in connection with an industry fundraising event or in connection with any event where you could be viewed as acting as an agent of Newmont, you must report the contribution to the government relations department as it may need to be attributed to the company contribution calculations. Failure to properly disclose all corporate contributions may subject involved individuals and Newmont to criminal and civil penalties, including fines, jail sentences and other criminal or civil sanctions.