Code of Conduct

The guide to bringing our values to life

 Newcrest Code of Conduct

Newcrest’s Code of Conduct Contents

is designed to clearly state
the way we conduct ourselves
in business with our internal
and external stakeholders.

Our values About our

Code of Conduct

03
Message from our Managing Director & CEO
Caring about people
04
Our responsibilities

04
Integrity and honesty Breaches of the Code

06
Speaking Out

Working together 60
Key contacts and resources

Innovation and problem solving

High performance

Our purpose

Creating a brighter future

for people through safe
and responsible mining

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document. You can click
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Contents 01

We care about We work We work with We protect We promote

our people together integrity & our resources sustainabilty
honesty

09 19 29 41 55
Human Rights and Workplace Behaviour Conflicts of interest Protecting Newcrest Environment, Social
Modern Slavery Our working relationships Throughout our global and Third Party Property and Governance
Central to our vision is are respectful, supportive business we act with We are committed to Sustainability is a vital
our commitment to live and professional. honesty and integrity protecting Newcrest component of our
by our values. The first and live our values. confidential information company vision to be
of our values is caring 22 and property at all times the Miner of Choice.
about people. Inclusion and Diversity 32 and making sure that we
We know that our different Bribery and Corruption only use it for the benefit 58
12 backgrounds, perspectives We strictly prohibit of the company. Climate Change
Health and Safety and experiences makes all forms of bribery, We are committed
The health and safety Newcrest a better place corruption and other 44 to the sustainable
of our people and to work and fosters related unlawful or Asset and Technology discovery, development
communities are our high performance. improper payments Management and production
highest priorities. We want or activities. Assets include physical and of gold and copper.
everyone to go home safe 24 non-physical property, such
and healthy every day. Communities and 34 as equipment, inventory,
Indigenous Peoples Gifts, hospitality and technology, intellectual
14 Our goal is to be the sponsored travel property, company
Security Miner of Choice for GHST can give rise to information and data.
Our people are our the communities we actual or perceived undue
greatest asset and nothing work with. influence. We carefully 46
is more important than consider all offers or Cybersecurity,
their safety and security. 26 receipts of GHST and Information and
Dealing with suppliers we only offer or receive Data Protection
16 and third parties GHST in accordance with We’re committed to
Privacy and personal We value our relationships our Business Integrity protecting Newcrest
information with our suppliers Standard processes. business information
We respect your privacy. and third parties and and data by applying the
We always follow relevant appreciate the role they 36 right level of controls
laws when we collect, play in helping us to Insider Trading and educating our
store, use and disclose achieve our goals. Insider trading occurs people on cybersecurity.
personal information. when you possess market
sensitive confidential 48
information in relation to Accuracy in Company
Newcrest and you trade Records
in Newcrest shares, or Using and handling
procure that someone else information in an accurate
trades in Newcrest shares, way is critical to our
or you pass on information integrity and reputation.
to a person who trades in It’s especially important
Newcrest shares. that our company records
are accurate.
38
Donations, Sponsorship 50
and Political External Communications
Contributions We communicate with
Newcrest strives to always media and other external
be a good corporate and stakeholders in a timely,
community citizen. fair and consistent way.

52
Social Media
Social Media is no
different to all other
external communications
about or referring to
Newcrest. We take
care to communicate in
accordance with our values.
02 Newcrest Code of Conduct

About our Code of Conduct

03 Message from our Managing Director & CEO

04 Our responsibilities
04 Breaches of the Code
06 Speaking Out
About our Code of Conduct 03

Message from our Managing Director & CEO

Each day I’m impressed by the efforts and talents of our
people. Your commitment and dedication to supporting
each other and our communities is inspiring.

Our success comes from the way we work together, the integrity
of our actions, and importantly, in the way we support each other
to ensure everyone is treated with respect and dignity and feels safe
to speak up.
Our continued growth will be built on a culture that embraces
diversity as a strength, recognises inclusion as a powerful driver
of progress, and where psychological safety is treated just as
importantly as physical safety.
Our Code of Conduct is our blueprint for the way we work.
Whether you’re an employee, contractor, community member,
supplier or stakeholder, our Code of Conduct sets the expectations
for people and the benchmark for all of us to live up to. It also
supports decision-making when faced with an ethical dilemma.
Embedded into our Code of Conduct are our values: Caring about
people, Integrity and honesty, Working together, Innovation and
problem-solving, and High performance. These guide how we
behave, as we work towards realising our vision – To be the Miner
of Choice.
Newcrest is a great company, with great people. I am incredibly
proud of the extraordinary outcomes we continue to achieve
together, as we create a brighter future for the people and
communities, we have the privilege to work with.
Please take the time to review our Code of Conduct and do your Sandeep Biswas
Managing Director and
part in Forging an even stronger Newcrest. I am excited about our Chief Executive Officer
future and working with you to ensure a Newcrest that supports
and empowers people to be their best, succeed and to thrive.

Our vision Our purpose Our edge

Be the Miner Creating a brighter Collaboration,

of Choice. future for people innovation and an
• Valued by our people and through safe and owner’s mindset.
communities.
• Respected by our partners,
responsible mining.
customers, suppliers and peers.
• Celebrated by our owners.
04 Newcrest Code of Conduct

Our responsibilities
This Code of Conduct applies to:
• All our directors, officers, employees, contractors, consultants • All our relationships with suppliers and joint venture partners,
and third parties who work for or work with Newcrest. to understand the way we work and expectations of our people.

Our expectations of our people Our expectations of our leaders

We expect you to follow our Code of Conduct, support our We expect our leaders to role model our Code of Conduct by:
values and comply with local laws.
•  elping team members understand and comply with the Code;
h
Our vision is to be the Miner of Choice for our people, • encouraging questions about the Code;
for the communities we work with and for our investors. • demonstrating our values in action;
Our Code of Conduct sets out how. It details what we stand • making decisions in the best interest of Newcrest; and
for, how we interact with stakeholders and what they can
• encouraging a culture of inclusivity and diversity.
expect from us.
We expect you to act responsibly, ethically, honestly and Our expectations of our partners
with integrity. Our Code of Conduct sets out how each of
us are expected to behave when we are at work. We expect the third parties that we do business with, including
governments, suppliers, joint ventures and industry associations to:
Your line manager, the Ethics & Compliance Team or the
Chief Legal, Risk and Compliance Officer can answer your • understand our expectations and standards of behaviour; and
questions about what the Code means and how it applies • observe the Code’s practices and guidelines.
to your work.
If it’s your job to work with Newcrest’s third parties, we expect you
to be aware of their behaviour and hold them accountable if they
breach the Code.

Breaches of the Code

It’s everyone’s responsibility to report breaches of the Code A breach is any behaviour that goes against our Code. Any breach
of Conduct, our values, the law or other behaviour or activity of the Code, or potential breach of the Code, must be reported.
of concern. If something doesn’t seem right, raise it with your line manager.
You can also report a breach or concern using Newcrest’s
confidential Speak Out hotline.

Our expectations of our people Consequences of violations

• Understand how the code applies to you. Breaches of the Code are taken very seriously as they compromise
• Follow the Code at all times. There may be a situation our values, practices and our culture of honesty and integrity.
that the Code doesn’t cover. In these cases, act in All breaches will be investigated thoroughly in line with our policies
accordance with our values and use your judgement and standards.
to make the most suitable and ethical decision.
Alternatively, seek guidance from your line manager If you breach the Code or our values, you could be disciplined,
or Ethics & Compliance Champion. including in the following ways:
• Know how and when to Speak Out. We expect you to • Counselling
Speak Out when you become aware of breaches of our • Training
values or the Code, breach of law or behaviour or activity
• Warnings – spoken and written
of concern for Newcrest.
• Stood aside from duty for a period of time
• Termination of your employment
About our Code of Conduct 05

Guidance compass

Don’t do it.

X Could it badly affect

Newcrest if X Wo
u
ing everyone did it? bad ld it lo
s it liv s? in a ok
I lue arti med
u r va cle
? ia
o X
w aff

Co t N old
X

od o

ul ew ers?
ec keh
r C oll

d
e?

st
ou it f

it b cres
a
es

ad t ’s X
Do

ly
Do the right thing
al?

It looks like
X
by Newcrest
Is it leg

you can
move forward.

It looks like

In practice

Scenario Response

I overheard a third-party consultant who’s working with our Our Code of Conduct applies to everyone, including
team talk to a government official about secret payments. third‑party consultants who work with or for Newcrest.
I’m not directly affected by the consultant’s behaviour and It’s your responsibility to uphold our high standards of ethical
I don’t have proof that they did the wrong thing. behaviour. Speak to your line manager about what you saw
and heard.
What should I do?
If you’re uncomfortable speaking to your line manager or with
their response, report the behaviour via our Speak Out channels.

Chris has recently joined our team and has a lot of If the behaviour breaches Our Code of Conduct or our values,
experience working for other miners. She suggests we do we don’t do it.
some things that she says are ‘common industry practice’.
Just because something is done by others doesn’t
I’m worried that some of the practices she’s suggested don’t
make it right.
follow the Code nor our values.
Show Chris our values and our Code to help her understand
What should I do?
her responsibilities as a Newcrest employee. Raise any
concerns you have with your line manager or via our Speak
Out channels.
06 Newcrest Code of Conduct

Speaking Out
Key to our Code of Conduct is that
we’re accountable and transparent.

Everyone who works at Newcrest shares a commitment to follow Our expectations of our people
the Code in word and in spirit.
All current or former Newcrest employees, officers, directors,
You’re encouraged to Speak Out about misconduct
contractors, consultants, suppliers or relatives of the above are
or concerns involving:
encouraged to Speak Out. Newcrest is committed to a culture
of trust, integrity and honesty. We support those who Speak Out • dishonest, fraudulent or corrupt activity;
and protect your confidentiality and anonymity, if requested, and
• illegal activity;
protect you from any detrimental treatment from doing so.
• safety issues;
You’re therefore encouraged to Speak Out about any misconduct,
anything that may be unethical or illegal, any safety issues or any • u
 nethical behaviour or serious breaches of our
serious breaches of the Code. We want to know about concerns policies or standards;
you are aware of. • b
 ehaviour or actions that present a real risk of damage
or harm to us, our people or third parties;
It takes courage and integrity to Speak Out about harmful
behaviour at work. Newcrest provides you with a choice of • b
 ehaviour or actions that could lead to financial loss
channels for reporting so you can Speak Out in the way you are or damage to our reputation;
most comfortable. Reports can be made to your line manager, • h
 arassment, sexual harassment or assault,
an Ethics & Compliance Champion, eligible recipients or online discrimination, victimisation or bullying;
or by calling our confidential hotline. Reports are treated seriously
• a breach of any law that may impact our business; or
and confidentially, and may be made anonymously. The Corporate
Ethics and Compliance team receive, triage, manage and • any other kind of serious misconduct or behaviour.
investigate, or appoint subject matter expert independent
investigators to investigate Speak Out reports. When a report
is investigated, it’s done fairly, competently, promptly and in
Personal work-related grievances or complaints about your
line with Newcrest’s standards and procedures.
current or former employment which are unlikely to impact
Newcrest’s business are better and more effectively managed and
reported to your line manager or People Business Partner, not as a
Speak Out. Examples include decisions about transfers, structure,
promotions, pay, performance management/discipline or the terms
of your employment. These personal work-related grievances or
complaints should be raised by following the Resolving Workplace
Behaviour Complaints Procedure or the Fair Treatment Procedure.

Learn more Who to contact for help

Speak Out Policy Speak Out Protection Officer


Ethics & Compliance Portal – Your People Business Partner or
Speak Out and Investigations guidance a member of the People Team

Fair Treatment Procedure Ethics & Compliance Champions

Workplace Behaviour Standard Group Manager Ethics & Compliance


Resolving Workplace Behaviour Chief Legal, Risk and Compliance Officer
Complaints Procedure
About our Code of Conduct 07

In practice

Scenario Response

Andrew works at Newcrest. He’s told Claire, his wife, about The Speak Out Protection Officer will take the following steps:
his suspicion that someone in his team has been behaving
1. Remove anything from Claire’s report that could identify
fraudulently. Andrew recently overheard some unusual
Claire or Andrew, such as names and email addresses.
conversations between this team member and Newcrest’s
suppliers. 2. Acknowledge receipt of the report and ask any clarifying
questions required to conduct a proper and fair investigation.
Claire sent an anonymous email to the Speak Out Protection
Officer about her husband’s observations and concerns. 3. Assess the complaint, consider whether it is protected
under Australian or other laws and ensure it is
What steps will be taken and what protections are
independently investigated. The investigation will follow
available to Claire and Andrew?
Newcrest’s Speak Out Policy and Investigation Guide and
principles of procedural fairness.
4. Conduct a ‘detrimental treatment’ risk assessment and
put in place steps to protect Claire and Andrew from any
repercussions of making the complaint.
5. Conduct the investigation in a timely manner and update
Claire, the reporter, on the progress and outcome of
the investigation.

I’m covering Luis’s job while Luis is on holidays. I received If you are concerned about potential corrupt activity –
a phone call where the caller thought I was Luis. The caller a serious matter which could impact Newcrest’s business
talked about us paying a bribe to someone who works for and/or reputation – you should report it.
one of our customers.
Raise your concern via one of Newcrest’s Speak Out channels:
I told my line manager and she said she’d deal with it. But
1. Your line manager;
when I brought up the topic again with my line manager
two weeks later, she told me “it’s nothing to worry about”. 2. Speak Out hotline – online or by phone;
3. Speak Out app;
I feel that the issue has been ignored.
4. Speak Out Protection Officer – by email, mail or phone;
What should I do?
5. Ethics & Compliance Champion; and
6. Eligible recipient – identified in the Speak Out Policy.

We do We don’t

Read and understand the Speak Out Policy. Disclose the identity or details of the person making a Speak
Out report, without their consent.
Report concerns of misconduct via one of the Speak Out
channels. Use the Speak Out channels for personal grievances or
complaints related to our employment. Instead, we first talk to
Investigate all Speak Out reports in a serious and confidential our line manager or People Business Partner and follow the
manner and treat all persons allegedly involved in a concern Fair Treatment or Workplace Behaviour Complaints Procedure.
fairly, including those named by someone speaking out.
Tolerate treating whistleblowers/Speak Out reporters badly
Securely store all paper and electronic records related to issues as payback for making a report. We don’t allow any reprisals,
reported via Newcrest’s various Speak Out channels. discrimination, harassment, intimidation or victimisation of any
reporters and protect people who make a report.

Ignore Speak Out reports. We consider, assess and

appropriately manage all reports received in line with our Policy.
08 Newcrest Code of Conduct

We care about our people

09 Human Rights and Modern Slavery

12 Health and Safety
14 Security
16 Privacy and personal information
We care about our people 09

Human Rights and Modern Slavery

Central to our vision is our commitment to
live by our values. The first of our values is
caring about people.

This means that we prioritise safety and health – we look after the
wellbeing of our people and the communities we work with.

Newcrest is committed to respecting the human rights of all

our employees, stakeholders and the laws of the countries we
work in. We care about how our operations could impact local
communities and respect the rights of neighbouring communities.
Respecting human rights means ‘doing no harm’.

Our commitment to human rights is key to

protecting Newcrest’s reputation as an ethical
business. These are the important issues that
we focus on:
• In the workplace, we respect our employees’
human rights.
• Our suppliers must respect human rights and
meet the expectations we’ve set out in our Human
Rights Policy, including preventing modern slavery.
We expect our suppliers to prevent child and forced or
compulsory labour and other forms of modern slavery,
avoid discrimination and observe workers’ rights by
respecting freedom of expression.
• The communities we work in have the right to an
adequate standard of living. This includes the right
to water and housing. We’re sensitive to how our
operations could impact local communities and
we remedy unavoidable adverse impacts related to
our operations.
• As we protect our people, operations and product, we
make sure we manage security in a responsible way.
We respect the rights of neighbouring communities.
We manage security risks in line with international
standards on the proportionate use of force.
International standards also govern our use of private
security providers or government security forces.
10 Newcrest Code of Conduct

Our expectations of our people

Everyone at Newcrest must respect human rights. Human rights risks can appear in any country and in any context,
This means you: so look out for new or developing risks. Remain alert to and report
any behaviour that doesn’t feel right. Tell your line manager,
• Must complete the online Human Rights Social Performance Team or your Ethics & Compliance Champion.
awareness training.
If a supplier, contractor or a community member wants to raise
• Encourage respect for human rights in your business
a concern or make a complaint they’re encouraged to report via
relationships and support human rights in your
our Speak Out hotline. Newcrest’s Speak Out Policy contains
relationships with our stakeholders.
more information.
• Recognise and respect the cultural values, traditions
and beliefs of the communities in proximity of our
operations. This includes Indigenous Peoples.
• Foster direct, honest and open relationships with
other people at work, built on mutual trust and
respect for every person’s dignity and worth.
• Check for and manage the human rights risks in our
operations and supply chain if it’s your role to manage
these relationships. Conduct human rights checks,
known as due diligence, regularly.
• Make sure that security is managed responsibly and
that human rights are respected if it’s your role to
secure Newcrest’s operations.

Learn more Who to contact for help

Human Rights Policy Your line manager

Communities Policy Ethics & Compliance Champion

Indigenous Relations Policy Group Manager Sustainability and Social Performance

Environment Policy Legal Corporate Counsel

Procurement Policy Chief Legal, Risk and Compliance Officer

Security Policy
We care about our people 11

In practice

Scenario Response

I overheard a conversation at our workplace between Our Procurement Policy requires that our suppliers respect
a cleaner and her supervisor that worried me. human rights and have procedures in place so they can do
what’s expected by our Human Rights Policy.
The cleaner was complaining that she hasn’t been paid
for her work and that her supervisor is holding her identity It sounds like what you saw and heard is not what we expect
documents so that she can’t leave. The supervisor told her from our suppliers.
to shut up and keep working.
Raise the issue with your line manager, your Ethics &
What should I do? Compliance Champion or via one of our Speak Out channels.

At my site we’re encouraged to offer jobs to the local We take the risk of using child labour very seriously.
community. Some of the people applying for jobs don’t
For this reason you’ll need to screen all job applicants in line
have official birth certificates.
with Newcrest’s recruitment processes. For at-risk workers
Is it ok to rely on the ages that people tell us as part of seek other reliable records.
their application?

We do We don’t

Respect human rights and build a good understanding of our Step back from our responsibility to look after people as caring
operating context in the countries where we work. for our people is one of our core values.

Make respect for human rights part of the way we work. We live Ignore human rights as that would be contrary to our values and
out our value of caring for people and consider the impact our could lead to negative, legal, financial and operational outcomes
work has on others. We follow Newcrest’s Human Rights Policy. and harm our reputation.

Listen to the opinions of others, support diversity and equal Think that the Human Rights Policy isn’t relevant because we
opportunity at work and contribute to a safe and healthy work outside Australia. The policy applies to every Newcrest
working environment. employee and contractor no matter where we are located.

Apply a human rights lens to our decision making and Avoid or take short cuts or risks in relation to supplier checks
work. This includes new business processes, acquisitions, and due diligence.
joint ventures and work with suppliers.
Skip the requirement that we complete online Human
Take the online Human Rights Training course available via Rights Training.
MyLearning. The Human Rights Training course covers all types
of exploitation including those identified in Australia’s Federal
Modern Slavery Act.
12 Newcrest Code of Conduct

Health and Safety

The health and safety of our people and
communities are our highest priorities. We want
everyone to go home safe and healthy every day.

In our workplace we believe all injuries are preventable.

We’re committed to zero fatalities and zero life-changing injuries. We improve safety in three ways:
Our vision is to have a lasting positive impact on the health • We continuously strengthen our safety culture.
and safety of our people. We achieve this vision by identifying
• Provide controls for every high-risk task.
risks to health and wellness and put in place controls and
safeguards. We set up health strategies to improve the health • Use the right systems and tools.
and prevent harm to our employees, contractors, customers
and neighbouring communities.
To prevent fatalities and life changing injuries we identify high‑risk
tasks, develop safety controls and verify the controls. We also target
wider system risks, such as the way our operating plants are designed,
together with precautions for chemical and energy hazards.

Our expectations of our people

Everyone has a role to play in reducing the risk of injuries Speak up when you see unsafe or unhealthy situations. Report
and harm to our health. You’re expected to do your part to these to your line manager. Take steps to deal with these situations
support a safe and healthy workplace. Each of us looks out when it’s safe to do so.
for each other’s health, safety and wellbeing. This means we
We each have a responsibility to make sure we’re fit to do our job
all take responsibility for upholding a workplace that’s free
safely. This includes not being impacted by tiredness, alcohol or
from unacceptable risk.
drugs. If you’re not fit to work, you must tell your line manager.
Only do tasks where you:
You’re empowered to make decisions that will keep you and other
• h
 ave the skills, knowledge, experience people you work with safe. This includes slowing down or stopping
(training and authorisation) and attitude to a task because it doesn’t feel safe. No task is so important that it
complete the task safely; can’t be done safely.
• u
 nderstand the timing and quality requirements
of the task;
• u
 nderstand the task’s hazards and the possible
outcomes of the hazards;
• u
 nderstand and agree to follow the hazard controls
that are required; and
• are fit for work.

Learn more Who to contact for help

Safety and Health Policy Your line manager

Safety Group Standard Health, Safety and Security Team

Health and Hygiene Standard Environment, Sustainability, Social Performance and

Cultural Heritage (ESSPCH)

Health, Safety and Security Portal
Employee Assistance Program
We care about our people 13

In practice

Scenario Response

I’ve recently been diagnosed with an illness and need to take You must ask your doctor how your illness and medication
medication every day. could impact your ability to safely do your job.
Do I need to tell my line manager about my medication? If your fitness to work could be impacted or you could
be harmed, you must tell your line manager. Your line
manager will work with you to make sure you get the
support you need.

I’m feeling pressured by my team to ‘do what it takes’ to get Everyone at Newcrest must follow health and safety controls
the work done. Sometimes this means we take shortcuts and for each and every task. No task should start or keep going
don’t put in place all the required safeguards. without these controls in place.
What should I do? Tell your line manager about your concerns. Know that
you’ll be supported if you stop the task. If you don’t feel
comfortable talking to your line manager, talk to your Health
and Safety Advisor or report via one of Newcrest’s Speak
Out channels.

We do We don’t

Follow the health and safety controls that apply to us at work, Assume that a health and safety problem has been solved
including mandatory personal protective equipment (PPE). We by other people.
also help others to follow our controls.
We ask, clarify and report.
Stop work when conditions or people’s behaviour create danger
Take shortcuts, rush or do tasks that we’re not skilled to do.
and report the circumstances immediately.
Ignore or downplay the health and safety concerns raised
Report any unsafe conditions, unsafe actions, injuries, illnesses,
by others.
incidents and near misses to our line manager.
Withhold declaring when we’re impacted by tiredness or
Speak to our line manager if we’re worried that a team member
anything else that harms our fitness for work.
could be unfit for work or unable to work safely.
14 Newcrest Code of Conduct

Security
Our people are our greatest asset and nothing is
more important than their safety and security.

We put people at the centre of our decisions and strive to create Our expectations of our people
a safe and secure workplace. Our approach to security takes
into account all stakeholders such as local communities and
governments. Our approach also shows our commitment to • W
 e all have a role to play in being aware of security
respecting human rights. risks and threats at work.
• If you see or hear something that doesn’t seem
right, we want you to speak up. Tell your line
Our security programs focus on:
manager or raise the issue via one of Newcrest’s
• protecting and respecting people; Speak Out channels.
• making sure that our security activities respect
and protect human rights;
• protecting our product; and
• protecting our assets.

We review the effectiveness of our security programs regularly

so we can continue to improve.

Learn more Who to contact for help

Security Policy Your line manager

Human Rights Policy General Manager Health, Safety and Security

Security Operations Standard Group Manager Security

Security and Human Rights Standard Ethics & Compliance Champion

Gold Security Standard

Security Code of Conduct Procedure


Health, Safety and Security Portal


Environment, Sustainability, Social
Performance and Cultural Heritage
(ESSPCH) Portal
We care about our people 15

In practice

Scenario Response

I’ve recently noticed things missing from the storeroom You should talk to your line manager about your concerns.
on-site which seems suspicious to me. The items aren’t
Even though the items aren’t costly, if the items are being
costly and can be easily replaced.
stolen, over time they can add up to major costs for your site
What should I do? and Newcrest.
We’re committed to providing our people with a secure
workplace. We want everyone to feel safe and secure at
work. So it’s important to speak up about suspicious activity.

How do I report a concern that I have about security If you’re concerned about reporting an issue to someone you
without putting myself at risk? work with, you can raise it via one of our Speak Out channels.
Or reach out directly to the Group Manager Security.

We do We don’t

Treat everyone with care and respect. We safeguard people’s Start, or continue to spread, inappropriate conversation about a
dignity and privacy. person’s private information that we are privy to due to our job.

Respect and follow local laws. As a foreigner in a country, defend our actions when deemed
inappropriate or contrary to local laws by arguing that our
Speak up or make a report if we see or hear something that actions are acceptable in our country of origin.
doesn’t seem right.
Ignore suspicious activities.
Play our part to prevent access to our workplace by people
who shouldn’t be there. Hold security doors open for people who we don’t know.

Take care with our keys and access cards. Lend our security passes to our team members.
16 Newcrest Code of Conduct

Privacy and personal information

We respect your privacy. We always follow
relevant laws when we collect, store, use
and disclose personal information.

We’re committed to making sure that when we collect, store, Our expectations of our people
use or dispose of information about you, we do it properly
and respectfully.
We only collect personal information from you if we need We expect everyone at Newcrest to follow our
this information to carry out our business operations and to Privacy Policy and Standard. This means that you:
comply with applicable laws. Sometimes we may also collect • Only collect, store, use and disclose personal
sensitive information because it’s required by workplace or information where it’s necessary to carry out our
equal opportunity laws and to improve our workplace diversity. business and is allowed by law.
For example, we may ask you for your vaccination status. At times
we also need to do criminal record and medical checks as part • Always treat the privacy and personal information of
of our work. If we need to collect sensitive information from you, other people with care and respect.
we will get your consent first. • Let the Privacy Officer know if your or someone else’s
personal information has been compromised as soon
Contact our Privacy Officer to get access to, or correct,
as possible.
the personal information that we hold about you. We may
need to verify your identity before giving you access to your
personal information.

Learn more Who to contact for help

Privacy Policy Your line manager

Privacy Standard Ethics & Compliance Champions

Ethics & Compliance Portal Group Manager Ethics & Compliance

Employee Records Standard Privacy Officer [email protected]

People Business Partner

We care about our people 17

In practice

Scenario Response

I’ve received a phone call from someone outside Newcrest You mustn’t disclose someone else’s personal information
asking for my team member’s contact details. without proper approval or consent.
What should I do? Ask your team member for their consent to disclose their
information and seek advice from your Ethics & Compliance
Champion if in doubt.

I and other members of my team have received an email It’s possible that there’s been a data security breach. Report
containing sensitive employee information. the email to the Privacy Officer for investigation immediately.
What should I do?

We do We don’t

Tell the Privacy Officer immediately if we suspect or know Access personal information without proper approval.
about a data breach related to our workplace.
Use personal information in a different way to the purpose
Collect personal information directly from individuals. it was collected for.

Tell people why we’re collecting personal information and Keep personal information for longer than is required to
how we plan to use the information. carry out our business operations.

Protect personal information from wrongful use, loss, Share personal information to anyone inside or outside
unauthorised access, modification or disclosure. Newcrest without proper approval or consent.

Follow Newcrest’s Privacy Policy, Standard and any relevant Stop anyone from updating their personal information or
legal requirements. making complaints about privacy concerns.
18 Newcrest Code of Conduct

We work together

19 Workplace Behaviour
22 Inclusion and Diversity
24 Communities and Indigenous Peoples
26 Dealing with suppliers and third parties
We work together 19

Workplace Behaviour
Our working relationships are respectful,
supportive and professional.

Any harassment, bullying or discrimination based on someone’s

ethnicity, race, religion, gender identity, sexual orientation, age,
physical appearance or disability is unacceptable in our workplace.

This means at Newcrest there is no place for: Our Respect@Work program ensures we’re:
• Harassment, which is unwanted behaviour that • Keeping our people both physically and
someone finds offensive, intimidating or humiliating. psychologically safe.
• Sexual harassment, which includes any unwelcome • Encouraging and supporting our people to speak up
sexual advance, unwelcome request for sex or other if they experience or witness disrespectful behaviour.
unwelcome sexual behaviour. The test is whether a
• Creating safe, inclusive and respectful workplaces.
reasonable person, in similar circumstances, would
expect the person harassed could be offended, • Aware of legal and cultural requirements.
humiliated or intimidated. • Continuing to positively influence what we believe
• Bullying, which is repeated verbal, physical, social or about each other.
psychological abuse of a worker by someone or group • Opening up the space for discussions on how we
of people. prevent sexual harassment and sexual assault.
• Discrimination, which is treating someone worse • Including best practice and continually building in
because of their ethnicity, race, religion, gender feedback from our people.
identity, sexual orientation, age, physical appearance
or disability.

These behaviours can significantly impact someone’s physical, We’re committed to providing you with a safe and respectful
emotional and psychological health. We don’t accept any of these workplace, as everyone has the right to feel safe when they
behaviours in our workplaces. come to work.
We educate and build our people’s awareness of these behaviours
and what harassment, sexual harassment and assault, bullying and
discrimination means. This is so that our workplaces are safe and
supportive for everyone.
20 Newcrest Code of Conduct

Our expectations of our people

Each of us has a responsibility to:

• Be respectful of everyone at work.
• Actively make our workplace a psychologically
safe place for everyone.
• Support and encourage each other to speak up
and start a conversation when something doesn’t
feel right.

If you experience or witness sexual harassment, sexual

assault, bullying or any other unacceptable behaviour
at work, we want to know about it. We want Newcrest
to be a safe place for you to feel comfortable to report
it. We encourage you to use our Speak Out channels
to do this or any of the other suggestions on the
Respect@Work Intranet site.

Learn more Who to contact for help

Inclusion and Diversity Policy [email protected]

Workplace Behaviour Standard Your line manager

Human Rights Policy Health and Safety

Trupla Man, Trupla Meri (PNG) Security

People Business Partner

Group Manager, Respect@work

Employee Assistance Program

Speak with somebody or a leader you trust on-site

We work together 21

In practice

Scenario Response

Someone at work comes into my personal space and strokes my If you feel safe to do so, let the person know you’re
arm. I feel uncomfortable. uncomfortable and ask them to stop the
What can I do? unacceptable behaviour.
If they don’t stop and/or to report the incident speak
to Health and Safety, Security, the People Team,
your line manager or someone you trust on-site.
Or make a confidential report via one of our
Speak Out channels.

My manager and others in my team sometimes talk about me If you're experiencing unacceptable behaviours
behind my back, use disrespectful nicknames to refer to me and call at work, please speak up and let us know. We're
me rude names which upset me. When I object to the things I hear, committed to providing you with an inclusive and
they tease me and tell me not to be so "sensitive". safe workplace.
What can I do? If you don't feel safe raising this with your line
manager or local People Business Partner you can
When I first arrived on site I overhead someone refer to me as "fresh report confidentially via our Speak Out Channels.
meat". I felt extremely uncomfortable being referred to in this way,
and it made me feel personally unsafe. It also made me question Alternatively, you can speak to a member of your local
whether I could ever be truly valued and included in the company. Health & Safety team, a Speak Out Protection Officer,
the Group Manager Respect@Work or someone you
Where can I go for help?
trust on-site who can assist you to report the matter
via the appropriate channels.
My manager swears and communicates aggressively in team
meetings, and I note that others in the team have also started doing
the same. It makes me feel disrespected and undermined, and it has
started to affect my and others' confidence – at work, and personally.
Is this behaviour acceptable?

We do We don’t

Respect each other and actively strive for a safe and Accept unwelcome familiarity including touching, staring
inclusive workplace. nor unwanted invitations to go on dates, requests for sex
nor intrusive questions about someone’s private life, body
Encourage and support our people to speak up when we or gender identity.
witness or experience disrespectful or unacceptable behaviour.
Make jokes, insults or tease people about their gender,
Appreciate and support everyone at work, especially when they appearance, religion, sexual orientation, race or ethnicity.
come from a different background to us.
Accept sex-based insults or taunts or sexually explicit emails
Use social media and digital tools appropriately and respectfully or SMS text messages.
of each other.
Distribute or display any inappropriate pictures, posters
Create a safe and inclusive workplace where people feel images or videos.
comfortable to express their thoughts and ideas.
Belittle, bully or physically intimidate others.
22 Newcrest Code of Conduct

Inclusion and Diversity

We know that our different backgrounds, perspectives
and experiences makes Newcrest a better place to
work and fosters high performance.

That's why inclusion and diversity are foundational to our vision, Our expectations of our people
values and company culture. We recognise that creating an
inclusive and diverse workplace will help us to find better ways
to collaborate, innovate and deliver a high performing culture. Each of us has a responsibility to:
Newcrest is being made stronger and more successful because
of our inclusivity and diversity. • Value and seek to understand the different backgrounds,
experiences and views that our global workforce,
We actively focus on attracting, retaining and developing diverse partners, contractors and communities bring.
teams and we work hard to make sure that everyone feels
welcomed, safe and valued at Newcrest. • Work together with people and communities who
may have different backgrounds to us so we can find
We want all employees to feel that they can be themselves at work. new ways to innovate and solve problems.
That you’re valued for who you are; that you feel safe to speak
• Employ, promote and pay people based on their
up and contribute. We’re committed to an environment where
skills or performance rather than their ethnicity, race,
everyone feels they belong at Newcrest and are supported and
religion, gender identity, sexual orientation, age,
empowered to succeed in their work and life.
physical appearance or disability.
Newcrest sets targets, measures and long-term aspirations
• Treat everyone with dignity and respect. Harassment,
for inclusion and diversity. We report on how our inclusion
intimidation or bullying of any kind is unacceptable in
and diversity plans are progressing to our Board and to
our workplace.
our stakeholders in our Annual and Sustainability Reports.
We recognise that creating an inclusive and diverse workplace is
everyone's responsibility and has benefits to all. We are committed
to embedding inclusion into all aspects of our culture, driven by our
leaders and our people, and impacting the workforce experience
at Newcrest.
We’re committed to maintaining a direct relationship with our
employees. Employees have the right to choose whether to belong
to a union and to have the union negotiate with Newcrest on your
behalf. Newcrest supports local laws and international workforce
labour agreements.

Learn more Who to contact for help

Inclusion and Diversity Policy Your line manager


Inclusion and Diversity Strategy FY21–FY25 Your People Business Partner

Workplace Behaviour Standard Senior Advisor – Inclusion and Talent

We work together 23

In practice

Scenario Response

My manager dismisses my contributions in team meetings, These behaviours do not align with our values and are not
and ignores my input in project decision-making. I also inclusive, respectful or acceptable behaviour. Newcrest is
feel that they take credit for my work which I think is unfair. committed to ensuring that you feel psychologically safe
My confidence has been eroded and I don't feel appreciated within the workplace, and that you are, and feel comfortable
or valued as a team member. to speak up. We take this commitment very seriously. We
care about our people and that means ensuring that our
What should I do?
day-to-day behaviours are professional, supportive, inclusive
and respectful.
These types of behaviour should be reported to your line
manager, if you feel comfortable doing so. Alternatively,
you can raise such concerns with your People Team or
confidentially, and anonymously if you choose, via our
Speak Out channels.

My background is very different from the other people in my Newcrest is an ambitious global business. It’s diverse
team. When we get together to make plans and decisions, thinking that’ll help us achieve our goals.
I often see issues differently to the rest of my team. Yet I stay
That’s why Newcrest values your ideas and opinions.
quiet because I don’t want to rock the boat.
It’s important that you contribute your views because a wide
Is this the right thing to do?
range of opinions helps Newcrest to make better decisions,
solve problems and innovate.
Your voice matters.

We do We don’t

Listen to others with empathy. Tolerate any type of discrimination, harassment or bullying.

Respect, value and include diverse experiences Turn a blind eye to behaviour that doesn’t meet our standards
and backgrounds. of respect, safety and inclusion.

Create work environments where everyone feels safe to Support behaviour, words or actions that exclude or dominate
speak up and contribute. others at work.

Challenge and call out behaviour that may exclude or Make assumptions about someone’s performance, potential or
disrespect others. ability based on their ethnicity, race, religion, gender identity,
sexual orientation, age, physical appearance or disability.
Show fairness and respect in all our work relationships.
Make jokes or comments about someone’s gender,
Encourage flexibility so that people’s commitments, work age, religion, race, ethnicity, sexual orientation, physical
and life goals are supported. appearance or disability.

Behave in a way that may be seen as offensive, insulting,

intimidating, malicious or humiliating to others.
24 Newcrest Code of Conduct

Communities and Indigenous Peoples

Our goal is to be the Miner of Choice for
the communities we work with.

We recognise and value the culture, customs and traditions Our expectations of our people
of these communities and work to achieve open and honest
long‑term, mutually beneficial partnerships.
Everyone at Newcrest, whether you’re an employee
or a contractor, must engage with all people and
We’re committed to the Free, Prior and Informed all communities respectfully, transparently and
Consent (FPIC) principle. This means we consult and accountably. This includes respecting:
engage with all communities that may be affected by
our operations in an inclusive way based on good faith. • rights and interests; and
So that communities can freely make decisions they’re: • special connections to lands and waters located on
• told beforehand and given enough time to be involved in lands traditionally owned by or under customary use
project decision making; of Indigenous and other peoples.

• fully informed about the potential impacts and benefits If it’s your role, we expect you to use extensive
of our work; and engagement and consultation processes. This is to make
sure Indigenous Peoples, communities and broader
• able to either give or hold back their consent to a project.
stakeholders can meaningfully participate in and support
informed decision-making. We expect you to obtain
the free, prior and informed consent of Indigenous
We are focused on preserving and managing cultural landscape communities, landholders and other communities
and cultural heritage resources. This includes Indigenous heritage, about issues that affect them.
industrial heritage and historic heritage.
We expect everyone at Newcrest to:
We work in partnership with communities and our approach
• Understand the importance of cultural landscape and
is underpinned by FPIC, Newcrest policies and international
cultural heritage management to the people we work
performance standards.
with and to Newcrest.
We acknowledge Indigenous Peoples, both past and present, as • Make sure you take every action to protect
the First Nation Peoples and custodians of the lands on which we Indigenous, historic and industrial heritage.
work. We apply internationally recognised principles and practices • Understand the importance of recognising and
in all our work with Indigenous communities. This includes upholding human rights in all the work you do with
engaging communities and people who may not be resident on Indigenous and non-Indigenous communities.
lands but maintain connection to those lands. We respect the
rights of Indigenous Peoples and their cultural heritage.

Learn more 
International Council on Mining and Metals
(ICMM) Principles
Communities Policy
IFC Performance Standards 5, 7 and 8
Indigenous Relations Policy

The Declaration on the Rights of Indigenous Peoples
Sustainability Policy

Human Rights Policy

Who to contact for help
Social Performance Standard Your line manager

Social Performance Guidelines General Manager Sustainability and Social Performance
(Cultural Heritage, Human Rights, Indigenous
Peoples and Stakeholder Engagement) General Manager Exploration
We work together 25

In practice

Scenario Response

We’re exploring a new site. Cultural heritage resources are important to the people
we work with and to Newcrest.
Why do I need to do a cultural heritage survey?
Surveys are essential to understanding where these
resources are so we can avoid them and manage risks
to the greatest extent we can.

I’ve been asked to work on a community project. Yes, all communities and people have cultural heritage
and knowledge. Non-Indigenous heritage is often called
Do non‑Indigenous communities have cultural heritage?
historic heritage.

We do We don’t

Follow laws, regulations and all voluntary commitments Disturb land without all the proper regulatory and
that we sign up to. company approvals in place. This includes the informed
consent of Traditional Owners, First Nations and other
Compensate people whose lands, waters and assets are impacted landholders.
impacted by our activity.
Pay people for access to land outside of the compensation
Report openly and without delay on our social and process or pay government officials to give us access.
sustainability performance.
Keep information to ourselves and only present the positive
Protect and manage cultural heritage resources in partnership opportunities. We don’t delay reporting issues and concerns.
with Traditional Owners, First Nations and landowners/holders.
This includes Indigenous, industrial and historic heritage. Disturb Indigenous and non-Indigenous cultural heritage
resources without getting all the permissions we require.
Exercise cultural sensitivity when engaging with both
Indigenous and non-Indigenous Peoples and communities. Go into a new community without carrying out proper
There may be customs, values and rules that need to be cultural due diligence. This goes beyond cultural heritage and
followed so we don’t offend. includes understanding values, norms and who the community
leaders are.
Follow site land disturbance procedures before any ground
work is carried out. Each procedure has cultural heritage Carry out activities on undisturbed land when an assessment
requirements that must be met. hasn’t been carried out.
26 Newcrest Code of Conduct

Dealing with suppliers and third parties

We value our relationships with our suppliers and
third parties and appreciate the role they play in
helping us to achieve our goals.

Because their role is so important, we’re committed to excellence Our expectations of our people
in how we deal with third parties and suppliers.
As third parties may play a role in acting for Newcrest, they can
impact our reputation. So we select third parties and suppliers that If it’s your job to work with our third parties,
share our values and way of working. we expect you to:
• be aware of their behaviour and to call them out if they
Our expectations of third parties breach our Code of Conduct; and
• maintain the highest level of ethical behaviour and
standards, most importantly if you work on our
Third parties have a responsibility to:
supply chain.
• Follow our Code of Conduct and Supplier Performance
If you work with government, you must follow all laws
Commitments when working with us, or when acting
that relate to your government relationships. When
for us.
dealing with government and public officials, you need
• Follow the law and our way of working in the countries to assess any potential for bribery or corruption, conflicts
we operate in. or reputational risks for Newcrest.
• Maintain the highest level of ethical behaviour and Record the details of all contact with government or
standards, notably if part of our supply chain. public officials. If you ask government or public officials
• Actively support our supplier due diligence processes. or their employees to do work for Newcrest, record the
terms and conditions.

We’re also committed to working with governments, their agencies

and their employees in an honest, open and ethical way. This
doesn’t mean that we agree with government policies or approve
of all government activities in the countries where we operate.

Learn more Who to contact for help

Procurement Policy Your line manager

Procurement Standard Head of Procurement

Business Integrity Standard Local Commercial Manager


Contract Management Process (CMP) Ethics & Compliance Champions
manual and training
Group Manager Ethics & Compliance

Procurement Governance Guidelines


Supplier Performance Commitments
We work together 27

In practice

Scenario Response

We’re thinking of using a local specialist equipment supplier. We expect our suppliers to actively support our due diligence
We’re doing our usual checks and the supplier isn’t giving process. These checks protect Newcrest from the risks of
us all the information that we’ve asked for. I’ve asked several sub-standard equipment, safety issues, breaches of our
times and also offered to help them. values and harm to our reputation.
This is the only supplier that said it would give us the Do not take risks or shortcut checks of our suppliers. Seek
equipment by the date that we need it. advice from your line manager, commercial manager or
Ethics & Compliance Champion.
Should I use the supplier anyway even though our checks
aren’t complete?

We’re conducting due diligence checks on a supplier we are This is a red flag and should be discussed with your line
proposing to use to supply tires. As part of this process we manager and brought to the attention of your Ethics &
identify that the supplier has been involved in a number of Compliance Champion.
bribery and corruption allegations, including fines imposed
You’ll be guided on further due diligence questions to
by ASIC, the Australian Regulator.
consider and whether or not to engage the supplier, taking
What should I do? into consideration potential legal and reputational risks
for Newcrest.

We do We don’t

Comply with Newcrest’s Procurement Policy and Standards. Provide any supplier or potential supplier with an unfair
advantage.
Speak up if we see unethical behaviour in our supplier
relationships or in their services. Try to get around Procurement or Delegation of Authority
controls.
Hold Newcrest and suppliers to account for what they say
they’ll do. Knowingly take part in or tolerate unethical behaviour in our
supply chains.
Conduct due diligence checks for potential legal or
reputational risks for Newcrest. Give, offer, promise, or provide money (or anything of value)
to third parties to wrongly influence their decisions.
Record our contact with third parties, including any terms
and conditions.
28 Newcrest Code of Conduct

We work with integrity and honesty

29 Conflicts of interest
32 Bribery and Corruption
34 Gifts, hospitality and sponsored travel
36 Insider Trading
38 Donations, Sponsorship and Political Contributions
We work with integrity and honesty 29

Conflicts of interest
Throughout our global business we act with
honesty and integrity and live our values.

Working with integrity and honesty means that you understand It is important that all our potential and actual conflicts of interest
when there’s potential for bias or have a conflict of interest with are identified, disclosed and appropriately managed to ensure
your duty to act in Newcrest’s best interests. Newcrest’s best interests are supported and maintained.
A conflict of interest occurs when you have a personal interest that We expect conflicts of interest to occur in our industry. To protect
could interfere with your decisions and actions when working and reputational damage to yourself and Newcrest it is important that
acting in Newcrest’s best interests. Conflicts of interest may be we’re made aware of any conflicts of interest. This is so appropriate
actual, potential or perceived by others to be a conflict, whether controls can be put in place to manage these conflicts.
they are in fact or not.

Examples of where a personal interest could create a Some conflict of interest examples which must be
potential conflict of interest include: disclosed include:
• Your relationships with relatives, ex-colleagues, • Having a personal business interest in an organisation
community groups or close friends. that you are aware is tendering for or supplying goods
• Your personal business interests or obligations. or services to Newcrest.

• Both financial and non-financial benefits for yourself, • Holding investments directly in assets or a business
or others connected to you. that you are aware is doing business with or on behalf
of Newcrest.
• Being involved in hiring, performance evaluating or
promoting relatives or close friends at Newcrest.
• Pursuing, awarding or maintaining Newcrest business
opportunities which may provide you, close family or
friends with direct or indirect personal gain.
30 Newcrest Code of Conduct

Our expectations of our people

As Newcrest employees our first loyalty is to Newcrest.

This means that we must ensure that our decisions are
made with Newcrest’s best interests in mind. We must
not put our own interests ahead of Newcrest’s, our
customers or the community.
You’re expected to immediately disclose all actual,
perceived or potential conflicts of interest through
Newcrest’s Conflicts of Interest Register. This is so that
these conflicts can be effectively managed. If you’re
unsure, talk to your line manager or an Ethics &
Compliance Champion.
If you’re a line manager, you must:
• regularly consider how your team’s function and
activities may impact your team’s risk profile; and
• make sure that your direct reports understand their
conflict of interest obligations and disclose all actual,
perceived or potential conflicts of interest.

Learn more Who to contact for help

Business Integrity Standard Your line manager

Ethics & Compliance Portal Ethics & Compliance Champions

Group Manager – Ethics & Compliance

We work with integrity and honesty 31

In practice

Scenario Response

I work in the People Team at Newcrest. My partner, Brian, Yes. If you engage Brian, there is an actual conflict of interest,
runs a training consultancy business. I need someone to due to your personal relationship and potential for personal
urgently present a training course and Brian is the obvious gain. The conflict remains even if he charged standard,
choice. He has the skills and he charges competitive rates. fair rates. You must disclose this conflict in the Conflicts of
Interest Register to ensure it is managed.
Is there a conflict of interest here?
Conflicts of interest may arise if you are connected to a
supplier, competitor, relative or someone at work. If so,
you must make sure that your personal interests don’t,
or don’t appear to, influence your decisions.

I told my close friend’s son about a job at our site. Disclose your conflict of interest and excuse yourself from
He’s applied. I’ve been asked to sit on the selection the selection panel as your close personal relationship to him
panel for the job. presents an actual conflict of interest.
What should I do? Stepping away from the selection process means you won’t
be in a position where it could be hard for you to make an
unbiased decision.
Excusing yourself also helps job applicants and the people
you work with to trust that Newcrest’s recruitment decisions
are fair.

We do We don’t

Regularly consider how our personal interests relate to our Hire, supervise or have decision-making influence over a family
duties to Newcrest. member or close friend.

Openly discuss with our line manager any conflict of interest as Do any type of paid employment for other employers while
soon as we know about it. working for Newcrest, unless approval has been given first.

Excuse ourselves from any decision making process that could Wrongly use Newcrest resources for our personal benefit or for
impact our ability to make impartial decisions. someone else’s benefit.

Report all actual, perceived or potential conflicts of interest in Act or make a decision that’s motivated by our own personal
Newcrest’s Conflicts of Interest Register. interests that are or may compete with Newcrest’s.

Damage Newcrest’s or our reputation by having undisclosed

and unmanaged conflicts of interest.
32 Newcrest Code of Conduct

Bribery and Corruption

We strictly prohibit all forms of bribery,
corruption and other related unlawful or
improper payments or activities.

Corruption occurs when people in positions of power act It doesn’t matter whether a bribe is made directly or indirectly, such
dishonestly or fraudulently for their own private gain. Bribery is as via an agent, or whether it’s successful or not. Even if accepted
a form of corruption, as is extortion, deception, collusion, cartels, in the local country, bribes are illegal in Australia and prohibited by
embezzlement and money laundering. Newcrest.
Giving, offering, receiving, promising or asking for any kind of Bribery and corruption in all its forms is unethical and illegal.
benefit to influence someone to get a business or personal It destroys trust, creates inefficiency and increases inequality
advantage is bribery. It’s unethical, a breach of trust and illegal. in the communities we work in.
Bribery takes many different forms and is not always obvious. We always work to the highest ethical standards and are
Bribes can be made using cash, charitable donations, paying committed to doing business with integrity and honesty.
travel expenses, unwarranted sponsorships, excessive gifts or
entertainment. Bribes also include payments for preferential
treatment or inside information and favours for relatives.

Our expectations of our people

Everyone at Newcrest must prevent all forms of bribery and corruption. We all work together to:

• Promote a culture that does not tolerate bribery or corruption. Newcrest can be responsible for the actions of third parties we
• Protect Newcrest against the risk of bribery or work with or agents acting on Newcrest’s behalf. So, if it’s your
corruption happening. role to manage our relationship with third parties, it’s important
that you’ve conducted checks and know who you’re dealing with.
To ensure this we don’t bribe or try to improperly influence
Check their business reputation and whether there are any clues
anyone to do anything different from their job requirements.
or indications from their past actions which we should be aware
Bribing someone not to do something when their job is to do
of when considering working with them. These checks, known as
that something is also wrong, such as turning a blind eye.
‘due diligence’ should be conducted regularly so we’re aware of
We don’t give, offer or authorise extra or off-the-record any relevant changes.
payments to speed up or get routine government tasks done,
Newcrest has developed group-wide controls to reduce the
such as processing applications for visas or licences. Paying
potential for bribery and corruption. Make sure you know what
extra for someone to do a normal part of their job is called
these are. Your site-based Ethics & Compliance Champions can
a facilitation payment. Even if it’s the local custom, we don’t
help with guidance and training.
make facilitation payments.
Whatever your role, ask for help if you’re not sure about what to do. If
Don’t give, offer or authorise secret payments/commissions to
you suspect bribery or corruption of any kind, it’s your responsibility
third party agents to influence the decisions of their business/
to make a report. Tell your line manager, an Ethics & Compliance
government connections. Even if a third-party agent applies
Champion or raise the issue via one of our Speak Out channels.
pressure, we don’t pay or receive secret commissions.

Learn more Who to contact for help

Anti-Bribery, Fraud and Sanctions Policy Your line manager

Business Integrity Standard Ethics & Compliance Champions

Donations and Sponsorships Policy Group Manager – Ethics & Compliance

Ethics & Compliance Portal Chief Legal Risk and Compliance Officer
We work with integrity and honesty 33

In practice

Scenario Response

My team is applying for an exploration licence overseas This may be a bribe even though the extra amount isn’t paid
and has employed an agent to help with local government directly. As the agent is acting for Newcrest, Newcrest could
negotiations. The agent asked for a large, extra amount for be prosecuted in Australia and/or the overseas country for
‘other fees’, which I understand will be used to make sure the foreign bribery depending on local laws. Fines and prison
local government provides the licence. sentences apply for individuals and the company.
What do I do? Don’t turn a blind eye to this behaviour. Make sure you’re
very clear on what you’re asking for, paying for and what’s
stated on invoices. Report any suspected or actual unethical
conduct to your line manager, Ethics & Compliance
Champion or via Newcrest’s Speak Out channels as soon
as possible.

A tender for supplying mining materials is being run by Sam, This is a bribe and is illegal. It could result in Newcrest paying
the procurement manager. I heard Sam asking Company too much for materials, sub-standard materials and possible
A for a cash payment in exchange for inside information safety issues.
about the other tenderers and to ensure Company A gets
If you’ve any suspicions about the transparency or fairness of
the contract.
procurement tendering processes, report them immediately.
Should I do something?

We do We don’t

Promote Newcrest’s commitment to eliminate bribery and Give, offer, authorise or ask for any kind of benefit with the
corruption in all its forms. intention of influencing someone to obtain an unjustified
business or personal advantage.
Appropriate due diligence and understand the interests of
companies and individuals we do business with. Allow any form of money laundering in connection with our
business activities.
Accurately and fully document relevant information about all
transactions when they happen. Offer or pay bribes, regardless of where we operate,
the circumstances or who is involved. Nor do we expect
Record conflicts of interest, gifts, hospitality, sponsored travel, our agents or third parties to do so.
donations and sponsorships in the relevant registers and obtain
required approvals. Hide transactions, gifts or receipts by splitting payments into
smaller amounts.
Report concerns or suspicions of bribery, corruption, improper
payments, fraud or any other form of unethical conduct to our Grant another person favours with the expectation of receiving
line manager or an Ethics & Compliance Champion. a benefit, such as a contract for a family company.
34 Newcrest Code of Conduct

Gifts, hospitality and sponsored travel

GHST can give rise to actual or perceived undue influence. We carefully
consider all offers or receipts of GHST and we only offer or receive GHST
in accordance with our Business Integrity Standard processes.

We don’t offer or receive any GHST in situations that could GHST includes all types of gifts, meals, hospitality, promotional
be, or look like, a conflict of interest or improper influence. sponsorship, donations, per diems, accommodation, car and
Any payment, gift, benefit or hospitality that could be seen vehicle hire.
to reward or encourage special treatment is also wrong.
People’s motives in offering GHST may not be bad. Regardless,
giving or receiving GHST may look like the person receiving the
gift will favour the gift giver when it’s time to take action.

Our expectations of our people

Don’t offer or receive GHST in situations where it could:

• cast doubt on your ability to make an independent Occasionally a per diem payment or honorarium payment is
decision and remain unbiased; or required by local law. If so, the payment must only cover the
• be seen as improper influence. regulated costs of public officials while they’re performing the
relevant official function. If required by local law, make the
Know the ‘Value Limit’ for GHST for your location, as set payment directly to a government institution or department and
out in the Business Integrity Standard. If you’re offered a make a record of this payment. Do not pay an individual public
gift that’s worth more than the Value Limit, the GHST must official directly.
be recorded in the GHST Register. This is so you can get You’re expected to follow Newcrest’s standards and policies
approval before you accept or provide the gift. If you’re given when considering, recording and getting approval for GHST. If
a ceremonial gift of significant value, you may accept it on you’re unsure about what’s appropriate to offer or receive, talk to
behalf of Newcrest and give it to your local People Manager. your line manager or your local Ethics & Compliance Champion.

Learn more Who to contact for help

Business Integrity Standard Your line manager

Donations and Sponsorships Policy Ethics & Compliance Champions

Anti-Bribery, Fraud and Sanctions Policy Group Manager Ethics & Compliance
We work with integrity and honesty 35

In practice

Scenario Response

I’m in the middle of a large business deal with Mr Prasad Since Mr Prasad is currently in a tender period with
on behalf of Newcrest. A team member has told me that Newcrest, you should decline his dinner invitation.
Mr Prasad is planning to present me with a 24-carat gold
Otherwise, consider whether the gift is, or could be seen as,
model of our joint venture exploration site at a formal dinner
in exchange for a business advantage.
in one week's time.
Expensive gifts must be declined or only accepted on behalf
What should I do? Do I accept the gift to keep Mr Prasad
of Newcrest. In this scenario it’s not clear if the 24-carat gold
onside? What should I offer Mr Prasad in return?
model is to be a personal or corporate gift.
When a gift’s value exceeds the Value Limit for your
location you must record and obtain approval through the
GHST Register.
If unsure, talk to your line manager or local Ethics &
Compliance Champion.

We’re considering using a particular supplier. The supplier The trip offer is extravagant and may be offered to, or
has offered me an expenses-paid tour of their factory in perceived to, persuade you to give them the contract.
another city.
This is potential bribery and unethical and should be
Included in the trip is a three-day, expenses-paid stay in rejected in line with our Anti-Bribery, Fraud and Sanctions
the city. Policy and Business Integrity Standard. It’s also against our
Code and values.
What do I do?
Report the offer to your line manager, your Ethics &
Compliance Champion or via Newcrest’s Speak Out channels.

We do We don’t

Understand and comply with Newcrest’s Business Integrity Request, offer, give or accept GHST in return for
Standard when giving or receiving GHST. business services, information or to obtain or provide
a business advantage.
Record and get approval for GHST when it’s required.
Give or offer unapproved GHST to a public official unless
Return or decline GHST that hasn’t been approved. required by law.

Hand over any ceremonial gifts of significant value that we’re Ask for GHST from anyone Newcrest does business with.
given to our local People Manager.
Offer GHST to an organisation or person currently involved
Check with our line manager or the Ethics & Compliance Team in a bid, tender or contractual negotiation with Newcrest.
when we’re unsure about whether to accept, return, decline or
give GHST. Give gifts, hospitality or payments to government officials to
speed up a service or to influence a decision. These payments
are known as facilitation payments and are prohibited
by Newcrest.
36 Newcrest Code of Conduct

Insider Trading
Insider trading occurs when you possess market sensitive confidential information in relation
to Newcrest and you trade in Newcrest shares, or procure that someone else trades in
Newcrest shares, or you pass on information to a person who trades in Newcrest shares.

Newcrest doesn’t tolerate insider trading. We’re committed to market sensitive information. Our policies and standards are in
making sure that our employees and the people connected to addition to laws and regulations that ban insider trading.
us act with integrity, particularly when buying and selling shares.
We also avoid the appearance of insider trading. This is to prevent
Our policies and standards forbid all employees from dealing in reputational damage to Newcrest and our employees.
Newcrest shares at specified times. You’re restricted further if your
role potentially gives you access to confidential and potentially

Our expectations of our people Our expectations of our designated persons

We expect everyone at Newcrest to be careful when If you’re a designated person, your role comes with
handling and storing Newcrest’s market sensitive additional responsibilities. Designated persons are:
confidential information. Don’t share confidential
• executives, general managers and managers
information with anyone else, including your family
(that is, Levels 3 or above); and
and friends.
• people who’ve been told by the Company Secretariat
As an employee of Newcrest, we encourage you to hold Team that they’re a designated person because
Newcrest's shares over the long-term. When you do buy their role gives them access to market sensitive
or sell Newcrest shares it’s important that you take care. confidential information.
In particular, you must not buy or sell Newcrest shares: If you’re a designated person, you’ll:
• at specified times when securities trading is • complete insider trading training every two years to
prohibited; or remind you of the key confidentiality obligations that
• when you are in possession of market sensitive apply to you; and
confidential information that would be likely to • ask the Company Secretariat Team for approval
impact share prices if made publicly available. before you buy or sell Newcrest shares.
These trading restrictions also extend to people with
a direct connection to you, such as your close family
members. The Securities Dealing Policy contains more
information about who’s a connected person and the
restrictions that apply to them. You’ll need to let your
connected persons know about these restrictions.

Learn more Who to contact for help

Securities Dealing Policy Your line manager


Keeping Important Company Information Chief Legal Risk and Compliance Officer
Confidential Guideline
The Deputy Company Secretary
We work with integrity and honesty 37

In practice

Scenario Response

At work I saw on the printer a document that referred to the You may have become aware of market sensitive
unexpected discovery of extensive new deposits at our site. confidential information.
It’s information that hasn’t been in the news and I haven’t
Trading whilst in possession of market sensitive
heard people on-site talk about it.
confidential information is illegal and known as insider
Can I tell other people at work or outside work about trading. If confirmed the result is serious civil and criminal
what I saw? penalties and reputational damage for you and Newcrest.
Do not share or use this information to trade in Newcrest
shares, without first checking on its market sensitivity with
the Company Secretary.

I’ve received Newcrest shares as part of my employee The restrictions in the Securities Dealing Policy relating
incentive plan. to trading do not apply to the grant of shares to you under
an employee incentive plan.
Do the insider trading restrictions in the Securities Dealing
Policy apply to these shares? However, the insider trading restrictions do apply to your
decision to trade and sell the shares. You must not use market
sensitive confidential information when making your decision
to do so.
Furthermore, under the Securities Dealing Policy, you must
not trade in shares during a prohibited period and if you
are a designated person, you must apply for prior approval
to trade.

We do We don’t

Take care when talking about what we’re doing at work and Disclose market sensitive confidential information or provide
what we see and hear. trading tips to others.

Protect market sensitive confidential information from being Discuss market sensitive confidential information in a place
accidently disclosed to others. where we could be overheard. We don’t let confidential
information be accessible to or visible to others.
Get approval from the Company Secretariat Team if we want to
buy or sell Newcrest shares and are a designated person. Buy or sell shares when we’ve learnt market sensitive
confidential information.
Complete online securities dealing training every two years if
we’re a designated person. Ask others to buy or sell shares for us, or suggest that someone
else buy or sell shares, when we have market sensitive
Ask our line manager, the Company Secretary or the Deputy confidential information.
Company Secretary if we’re unsure whether certain information
can be shared or whether we can trade in shares. Trade in Newcrest shares during prohibited periods.
38 Newcrest Code of Conduct

Donations, Sponsorship and Political Contributions

Newcrest strives to always be a good
corporate and community citizen.

This includes having a positive social impact in the communities We make our donation and sponsorship decisions based on
where we operate and, where appropriate, helping out through a clear understanding of the payment’s purpose. In the case
donations and getting involved in sponsorship activities. of sponsorships, we objectively analyse how the sponsorship
would benefit both the recipients and Newcrest.

Our expectations of our people

If it’s your role to make donation and sponsorship recommendations or decisions

make sure that you have conducted your due diligence and check that:

• all proposals fit with Newcrest’s strategy and meet the It’s important that due diligence checks are also done on the
criteria set out in our Donations and Sponsorship Policy; people or organisations that will receive the benefit. We must
• you understand the initiative’s impact on the environment understand who the ultimate beneficiaries of the donation or
and the community; sponsorship are and whether there is any reputational risk for
Newcrest. This includes checking that the donation or sponsorship
• the donation or sponsorship has been budgeted for in isn’t linked to:
annual budgets;
• a public or government official. This is because Newcrest never
• safeguards are in place such as approval by
makes political contributions and doesn’t sponsor political
someone with the right financial delegation and
activity; or
counter‑signatures;
• existing or potential customers. This is because there’s the risk
• you monitor payments and check that Newcrest’s
that the payment could be seen as a bribe.
procedures are being followed;
• you monitor donations and sponsorships for performance If you’re unsure talk to your line manager, Ethics & Compliance
against projected outcomes; Champion or the General Manager Environment, Sustainability
• you check that funds have reached the right destination and Social Performance.
and have been spent properly; and
• all donations and sponsorships are recorded in the
Donations and Sponsorship Register.

Learn more Who to contact for help

Donations and Sponsorships Policy Your line manager

Security Policy Group Manager Sustainability and Social Performance

Business Integrity Standard Ethics & Compliance Champions

Anti-Bribery, Fraud and Sanctions Policy General Manager Environment, Sustainability and
Social Performance
Social Performance Standard
We work with integrity and honesty 39

In practice

Scenario Response

I’m trying to organise a sponsorship for a community event. Donations and sponsorships are a risk because they can
be an easy way to channel bribes. There’s also a risk that
Why do I need to jump through so many hoops when I’m
donations/sponsorship can be used to obtain personal
happy to pay for the sponsorship out of my budget?
benefit via receipt of kickback payments in exchange for
commercial promises/information.
Follow the Donations and Sponsorship Policy together with
all checks and processes. These have been set up to protect
both yourself and Newcrest.

A local official is campaigning for re-election. She’s asked me Newcrest never sponsors or makes donations to any political
if she can use our company’s seminar room to host a fund party, politician, elected official or candidate or contributes to
raising event for her campaign. She said it’ll be at night on a political fundraising.
weekend so there’d be no inconvenience to us.
Use of company facilities is an in-kind benefit. The local official
What do I say? could favour our company unfairly or seek to reward you
personally which would be corrupt behaviour.
Use of our premises could also seriously harm Newcrest’s
reputation as it could look like Newcrest supports the local
official’s political activities.

We do We don’t

Get approval from our line manager before offering a community Provide donations or sponsorships to individuals, unless
donation or sponsorship. it relates directly to and supplements our employees’ own
charitable efforts.
Get approval from our line manager before involving Newcrest
in any business activity that’s linked to any political party or Accept a donation that’s aimed at wrongly influencing a
political activity. business decision or to obtain favours.

Undertake due diligence on recipients of donation or Make donations to any political party, politician, elected
sponsorship money to identify links and risks. Always follow official or candidate for public office in any country on behalf
financial safeguards. of Newcrest. Newcrest never makes contributions to political
fundraising events.
Make sure that our personal interest in an organisation doesn’t
create a conflict of interest as an employee of Newcrest. We Make cash payments of donations or sponsorship to individuals.
keep our personal interests separate from our work.
40 Newcrest Code of Conduct

We protect our resources

41 Protecting Newcrest and Third Party Property

44 Asset and Technology Management
46 Cybersecurity, Information and Data Protection
48 Accuracy in Company Records
50 External Communications
52 Social Media
We protect our resources 41

Protecting Newcrest and

Third Party Property
We are committed to protecting Newcrest
confidential information and property at
all times and making sure that we only use
it for the benefit of the company.
Newcrest property includes physical property such as facilities,
equipment, vehicles, computers and information technology
systems. It also includes financial assets such as money
and non-physical property such as intellectual property and
confidential information.
Intellectual property includes patentable inventions, registered
designs, copyright works and trademarks. Confidential information
includes commercially sensitive information, business information
and data, trade secrets, confidential operating procedures and
know-how. Intellectual property and confidential information
are found across our business. It’s in operational processes,
specifications, plans, drawings, financial data, equipment, software,
branding and written documentation.
Intellectual property and confidential information are strategic and
valuable assets. Their value can be lost if not managed correctly.
Risks include sharing or using it in the wrong way, incorrect
contractual wording and a failure to seek proper safeguards.
We are committed to complying with applicable laws in relation
to intellectual property. We also respect the intellectual property
rights and confidential information of third parties. Using
intellectual property and confidential information of third parties
in the wrong way can result in disputes. It can also damage
Newcrest’s reputation.
42 Newcrest Code of Conduct

Our expectations of our people

Everyone at Newcrest must protect Newcrest property It is also expected that you respect the intellectual property and
against damage, loss, theft or unauthorised access. confidential information of third parties such as our suppliers
It is expected that you: and competitors. Only use and share the intellectual property
and confidential information of third parties as allowed by
• Only use Newcrest property when it’s required by
confidentiality agreements and third-party licensing terms.
our work and to benefit the Company.
• Always follow our policies and procedures. If you’re unsure, talk to your line manager or the Legal Team.
• Do not change, destroy, throw away or take Tell your line manager or consult with Legal if you:
Newcrest property without the right approval. • Suspect fraud, theft or wrongful use of Newcrest property.
• Do not share Newcrest’s intellectual property or
• Suspect or become aware of the wrongful use of third-party
confidential information without the right approval.
intellectual property or confidential information.
• Set up confidentiality agreements or make sure
that third parties have agreed to confidentiality • Think intellectual property could or has been created out of
in writing before you share intellectual property a project or work with third parties. Legal can make sure that
and confidential information. Newcrest has the right contract terms and other safeguards
in place.
• Return all Newcrest property at the end of
your employment.

Learn more Who to contact for help

Intellectual Property Strategy Your line manager


Information Technology and Data Legal Team
Management Policy
We protect our resources 43

In practice

Scenario Response

At work I invented a device that’s helping our team to be As set out in your employment contract, all intellectual
more efficient. I think it could also help other companies. property created while you are working for Newcrest
belongs to Newcrest.
Who owns this intellectual property?
This means that you cannot use it for non-Newcrest
purposes without first obtaining permission to do so
from Newcrest.

I’m finishing up my work at Newcrest. There are a few things When you finish up at Newcrest, you must return all
from my work that I’d like to keep. Newcrest property.
What can I keep and what must I leave at Newcrest? This includes returning books, access cards, notebooks,
software, computers, credit cards, keys, mobile phones,
security passes and vehicles.
You also need to return documents that include confidential
information or relate to the business of Newcrest or any
customer or supplier of Newcrest.

We do We don’t

Set up confidentiality agreements with third parties before Misuse Newcrest property for our own private benefit.
starting negotiations or sharing Newcrest’s intellectual property
or confidential information. Change, destroy, throw away or take Newcrest property
without the right approval.
Respect intellectual property and confidential information
of third-parties by complying with third-party confidentiality Share Newcrest’s intellectual property and confidential
agreements and licence terms. information without the right approval and a confidentiality
agreement in place.
Only use Newcrest property when required for your work and
for Newcrest’s benefit. Let third parties use Newcrest’s trademarks and logos without
the right approval.
44 Newcrest Code of Conduct

Asset and Technology Management

Assets include physical and non-physical property,
such as equipment, inventory, technology, intellectual
property, company information and data.

We take care of our assets by doing the right operational, technical Our expectations of our people
and maintenance work at the right time. Asset and Technology
management also includes using the right plant and equipment,
tools, parts, skilled workforce, applications, networks and systems We all have an obligation to safeguard our assets and to
as set out in our standards, so we work safely and maximise value. use them appropriately. We never knowingly misuse or
We protect our assets throughout their lifecycle, from design cause damage to our assets.
through to disposal and strive to optimise their reliability across the Our responsibility to safeguard our assets also includes
production value chain. Robust information security is a primary preventing and detecting fraud.
consideration when designing, implementing, and using our assets
and technology.
This approach helps us to meet our safety, environmental,
operational, and financial goals and reduce risks and costs.

Learn more Who to contact for help

Asset Management Diagnostic Guideline Your line manager

Asset Management Standard Site IT Superintendent


Information Technology and Data Cybersecurity Advisor
Management Policy
Group Manager, Security

Keeping Important Company Information
Confidential Guideline

Security Policy

Information Technology Usage

Acceptance Form
We protect our resources 45

In practice

Scenario Response

There’s software that I want to help me do my work. No. Only authorised and approved software is allowed
on your Newcrest device. Installing unapproved software
Can I download and install the software onto my
could put your device at risk of viruses or other malicious
Newcrest device?
cyber vulnerabilities. If you require other software, ask the
IT Service Desk. Remember, it is your job to keep your
Newcrest provided devices safe.

My manager has a personal business. He uses Newcrest’s Newcrest’s assets should only be used for Newcrest work.
assets for his business including Newcrest meeting rooms You shouldn’t do or be asked to do work for an unrelated
to meet with his customers and sends personal parcels on business during Newcrest work time.
Newcrest’s courier account. He also asks me to do small
Using Newcrest assets for a non-Newcrest matter may
tasks for his business during work time.
amount to theft/fraud.
Is this acceptable? What should I do?
Seek guidance from your local People Team, Ethics &
Compliance Champion or report via the Speak Out channels.

We do We don’t

Use Newcrest assets for company purposes only. Use Newcrest assets for personal gain.

Report any theft, misuse, loss, or fraud of our assets. We report Permit unauthorised access to Newcrest sites or offices or
the loss (such as a lost laptop) or theft of Newcrest information access to our data or information technology.
to our line manager immediately.
Share sensitive data without approval.
Keep devices containing information that relates to Newcrest in
a secure location. Try to access sensitive data within applications without
approval to do so.
Use work resources in the way that they’re intended to be used.
46 Newcrest Code of Conduct

Cybersecurity, Information
and Data Protection
We’re committed to protecting Newcrest business
information and data by applying the right level of
controls and educating our people on cybersecurity.

We’re always improving our cybersecurity capability across Our systems, assets and data are the property of the Company.
Newcrest to prevent viruses, cyber-attacks, theft of our data and This includes Newcrest data stored both on your Newcrest devices
damage to our reputation. and your personal devices.

Our expectations of our people

Everyone is responsible for keeping our systems and • Your Newcrest email address should only be used for work
data safe. Whether you’re an employee, business partner and never be used for personal purposes. So don’t use your
or contractor, we all must play our part. So when you Newcrest email address when signing up to websites such as
use Newcrest’s information technology and operational career or social media sites.
technology, always follow our company policies, standards, • Use applications recommended in the Application Usage
procedures and guidelines. Standard to safely and securely store documents. Never save
Here’s how you can help keep our systems and data safe: Newcrest documents on your PC hard drive, external storage
device or other locations such as Dropbox that aren’t secure
• Don’t share your Newcrest passwords with anyone,
or backed up. Don’t copy or transfer files that break any
especially people outside the Company. Don’t write or
copyright laws.
store your password in a way that could be worked out
by others. • Use Newcrest-owned devices and software in the way they’re
intended. Safeguards have been set-up, so don’t remove
• If you send our business data to third parties, you need to
Newcrest mobile applications or device management software
ensure you conform to the Information Technology and
from your company phone or tablet. If you get a security
Data Management Policy. Depending on the type of data,
notification or message, don’t ignore it. Company assets or
you may need the approval of your line manager first. We
employees could be at risk.
don’t share business data with others when there isn’t a
valid business or legal need. • Unsecured networks are unsafe. Don’t connect Newcrest
devices to them.
• Don’t forward emails from your business email address
to your personal email address. This is to keep our data If you’re unsure about how to use our systems or devices, ask your
confidential as external email providers and personal line manager or Newcrest Information Technology for training. Ask
devices are outside our safeguards. The Information the IT Service Desk if you need software or information technology
Technology and Data Management Policy sets this out. services from a supplier or third party.

Learn more Who to contact for help

Security Policy Your line manager


Information Technology and Data Site IT/OT Superintendents
Management Policy
Manager Infrastructure and Cybersecurity
Information Technology Usage
Acceptance Form


Keeping Important Company Information
Confidential Guideline

Social Media Standard

IT and Platforms Portal

We protect our resources 47

In practice

Scenario Response

I think I’ve received a phishing email? Click on the Report Suspicious button on your Outlook client
menu bar. Do this either on your laptop or mobile device.
What should I do?
You must also contact the IT Service Desk if you’ve
accidentally clicked on a link that looks suspicious.

I want to share information and data with a supplier. First, always check and verify the identity of the third party
when asked for information. If the request is not expected or
What’s the best way to do this securely?
unusual, ring or text them, rather than using email, to confirm
that the request is legitimate.
Second, use a secure and protected method to share data.
Refer to the Application Usage Standard and guidelines on
options to share data securely.

We do We don’t

Question all requests for access to confidential information or Download or copy illegal content from the internet or
login user names or passwords from people inside and outside storage devices onto Newcrest devices. Examples include
the Company. pornography or anything of a sexual, sexist, derogatory or
discriminatory nature.
Ensure that our Newcrest devices are up to date with security
Illegal downloads can also expose us to cyber-attacks.
updates and fixes provided by Newcrest. This is so that they
don’t create security problems for our systems.
Install unapproved apps or systems onto Newcrest devices.
Lock our screens when leaving them unattended.
Provide information that isn’t public to any person or company
without the proper approval.
Protect and maintain the confidentiality of information about
our business, plus details about our people and stakeholders.
Open attachments or click on links in emails that come
from senders who we don’t know or are in emails that we
Register for Mandatory Multi Factor Authentication to provide
don’t expect.
extra protection for our systems.
Use any storage solutions that haven’t been approved such
as hard drives, USB's, personal emails or personal cloud
environments to send, receive or store Newcrest data.

Re-use passwords that we’ve used before. Make sure

the passwords that we use for work aren’t also used for
other websites.
48 Newcrest Code of Conduct

Accuracy in Company Records

Using and handling information in an accurate way is
critical to our integrity and reputation. It’s especially
important that our company records are accurate.

Each of us create company records when we send emails, write Our expectations of our people
memos, reports and presentations. Company records include
financial and non-financial information and accounts. We all have
a part to play in keeping accurate company records. This is so that You must make sure that the information you record or
Newcrest continues to meet its obligation to keep the market fully report is honest, accurate, timely and transparent. It’s
informed about our activities. Our stakeholders rely on us to be important that the records you create don’t give a false
open and honest. view of the state of our business. Whether you’re writing
a negative or a positive report, you need to bring the
same clarity and honesty.
Our values – integrity and honesty, caring about people,
high performance, working together, innovation and
problem solving – guide how we communicate and
record information.
We also provide you with standards and policies to help
you. We must follow these internal standards as well as
financial, legal and regulatory requirements.
If you see or suspect something, or a report doesn’t
seem right, then please speak up.

Learn more Who to contact for help

Document Management Standard Your line manager

Market Releases and Investor Relations Policy Ethics & Compliance Champions

Media and External Communications Policy Company or Deputy Secretary

We protect our resources 49

In practice

Scenario Response

My team are capable and trustworthy. You must check the information and ask questions to make
sure of your understanding.
Is it ok to assume the information they prepare for external
release is accurate when I sign it off? You need to satisfy yourself that the information is reliable
before signing it off.

I help my team process invoices and expenses. When you put through a financial transaction, you need
to check that the source documents, such as invoices or
What evidence do I need to check and keep to support
receipts, are accurate and complete. You must also save
these financial transactions?
source and supporting documents in Newcrest’s systems.

We do We don’t

Keep accurate, complete and true company records in line with Encourage or allow others to do something that would harm
relevant laws, regulations, policies, standards and procedures. the accuracy or integrity of company records.

Follow company standards and procedures to make sure all Conceal, change or fake records or lie about any facts or
transactions are properly approved and accurately recorded. situations in company records for personal gain or for other
reasons. For example, changing records to try to get a bonus,
Cooperate fully, openly and honestly with internal and external a pay rise, a promotion or commission.
auditors, relevant authorities and regulators.
Destroy company records unless we’re confident it’s ok to do so.
50 Newcrest Code of Conduct

External Communications
We communicate with media and other
external stakeholders in a timely, fair
and consistent way.

As a publicly listed company, we follow laws about how Our expectations of our people
we disclose information so that investors can make
informed decisions.
Sometimes you may know confidential or sensitive
information as part of your work, which must not be
shared unless you’re authorised to do so.
You may have the opportunity to present at or be on
a panel discussion at an external conference. Before
accepting, you should ask yourself whether the
event relates to your job, if there’s a clear benefit for
Newcrest and importantly get approval from the Head
of Group Communications.
Speak to your line manager or Group Communications
if you’re unsure about:
• how to engage with external stakeholders; or
• what can be shared outside Newcrest.

Learn more Who to contact for help

Media and External Communications Policy Head of Investor Relations

Market Releases and Investor Relations Policy Head of Group Communications

Market Disclosure Policy Communications Manager/Officer

Social Media Standard

Internal Communications Policy

We protect our resources 51

In practice

Scenario Response

At a weekend BBQ, I shared sensitive information with my If you think you’ve released sensitive information that hasn’t
sister. She’s an equity analyst. The information hasn’t been been disclosed to the public, you must immediately report it
disclosed to the public yet. to Investor Relations, a Disclosure Officer or the Company or
Deputy Company Secretary.
What should I do?

At an industry presentation a colleague put up a slide that This may be material information that hasn’t been disclosed
included a photo of the new block cave we’re working on at to the public.
site. I’m pretty sure we haven’t notified investors.
You must immediately report it to Investor Relations, a
What should I do? Disclosure Officer or the Company Secretary.

We do We don’t

Follow laws and Newcrest policies about external Make public statements on behalf of Newcrest, unless we’re an
communication. authorised spokesperson.

Make sure any authorised public communication is clear, timely, Share material information unless we’re authorised to do so.
fair and consistent.
Use Newcrest trademarks or branding unless we have the
Avoid disclosing or publishing confidential company information. appropriate permission.

Respect confidential information and copyright laws. Speak to the media about Newcrest without first talking to
Group Communications.
Make sure we know what our local site requirements are and
follow them. Local sites may control the use of mobile phones, When making a public disclosure, hide facts or leave out
taking photos, video and audio recordings. relevant information.

Tell our line manager if we’re going to an industry or networking Speak at an event on Newcrest’s behalf without the guidance,
event or if we’ve been asked to speak at an external meeting. support and approval of Group Communications.
52 Newcrest Code of Conduct

Social Media
Social Media is no different to all other external communications about
or referring to Newcrest. We take care to communicate in accordance
with our values.

Our policies and standards for external communication also apply Social media gives us the chance to share our story with people
to social media. outside the company – our communities, our investors, our industry
peers, governments and potential employees. It’s important that
we do this responsibly.

Our expectations of our people

You’re empowered to speak positively about Newcrest on Establishing new external groups, sites or pages using the
social media. We encourage you to interact with our official Newcrest name or logo is not permitted without the right
posts by liking, commenting and sharing. approvals. Establishing accounts using Newcrest’s name or
logo can harm Newcrest’s reputation. You could also undermine
If you want to share Newcrest information on your
Newcrest’s official social media channels. Only official Newcrest
own personal social media account, you’re strongly
social media accounts can use Newcrest logos, trademarks and
recommended to take a common-sense approach.
other intellectual property. Contact Group Communications if you
Remember that your comments, likes and shares are public
see unofficial accounts using Newcrest or joint venture brands.
for all the world to see. Even if you don’t mention Newcrest
in your posts, they may still give the impression that they Make sure you read and understand our Social Media
represent the company. This could be because Newcrest is Standard. Speak to your line manager or Group Communications
mentioned in your bio or you wore a Newcrest branded shirt if you’re unsure.
in a posted photo.
Make sure you understand the difference between
what you can share in public and the role of authorised
spokespersons. Don’t discuss any confidential or sensitive
information about Newcrest on social media. Consult
the Social Media Standard, your line manager or Group
Communications if you’re unsure.

Learn more Who to contact for help

Social Media Standard Your line manager

Media and External Communications Policy Group Communications Team


Information Technology and Data
Management Policy

Workplace Behaviour Standard

Privacy Policy
We protect our resources 53

In practice

Scenario Response

I saw a post on Facebook about something taking place at No. Unless you’re an authorised spokesperson, you aren’t
site that I know isn’t true. permitted to comment on Newcrest’s behalf.
Can I make a comment to correct the information? Report the post to Group Communications.

I took a great photo of my teammates on-site with our open Each site has its own rules around photography. Ask your line
pit in the background. Everyone is in full PPE. manager about the rules for your site.
Can I post this on Facebook? You also need to ask your teammates if they’re okay with
their photo being posted on social media.

We do We don’t

Interact with Newcrest’s official posts by liking, commenting Use our Newcrest email address to register on social media
and sharing. platforms for personal use.

Talk about the parts of work we enjoy on social media. For Publish or disclose confidential or sensitive company
example, taking part in a fundraising event at work, attending information.
an industry conference or sharing published industry research.
Create our own Newcrest social media accounts.
Respect the privacy of people at work, customers, business
partners and communities. Respond to questions or negative comments on official
Newcrest social media accounts, unless we’re authorised.
Make sure our social media profile and posts are consistent
If we see comments that need a response, we send them to
with how we present ourselves at work.
Group Communications.
Take care when asking colleagues at work to be ‘friends’ on
Speak negatively about our workplace on social media.
Facebook or Instagram.
Regardless of our privacy settings, our posts can get shared
LinkedIn is a good place for connecting professionally with
publicly. Even after a post has been deleted, it can be tracked
work colleagues.
back to the person who posted it. Anonymous and closed group
posts can also be tracked back to the person who posted them.
Make sure our personal use of social media during work
hours doesn’t distract us from our job or stop us from delivering
our work.
54 Newcrest Code of Conduct

We promote sustainability

55 Environment, Social and Governance

58 Climate Change
We promote sustainability 55

Environment, Social and Governance

Sustainability is a vital component of our
company vision to be the Miner of Choice.

It’s also key to our purpose of creating a brighter future for people Our integrated approach to sustainability can be seen across
through safe and responsible mining. Newcrest. It starts with the charter of our Board’s Safety and
Sustainability Committee and our Sustainability Policy. Our Board’s
Safety and Sustainability Committee oversees the sustainability
It’s our aim to be: programs that are driven by our Executive Committee.
• a safe and sustainable business where everyone goes
home safe and healthy every day; and
We’ve also made public commitments to sustainability
• trusted by communities because of our environmental that align with these industry memberships:
and social record.
• International Council on Mining and Metals;
• World Gold Council; and
• Minerals Council of Australia.

We have a range of sustainability-related policies. They are about

climate change, energy, biodiversity, water stewardship, human
rights, Indigenous relations and community relations.

Sustainable mining means: We also set annual business objectives for sustainability to drive a
culture of continual improvement in sustainability across our business.
• engaging with and respecting local communities;
• checking for and managing safety, social and
environmental impacts; and We focus on four key areas:
• making ethical and transparent strategic business • everybody going home safe and healthy every day;
decisions that take into consideration present needs
• caring for the environment;
as well as future requirements of neighbouring
communities, stakeholders and the company. • developing and maintaining strong relationships with
our communities and governments; and
• acting ethically and transparently.
56 Newcrest Code of Conduct

From an investor perspective, sustainability can be described Our expectations of our people
as environment, social and governance (ESG). Newcrest can be
compared with other companies through ESG indexes such as the
Dow Jones Sustainability Index (DJSI).
We take a broad view of sustainability and each year we conduct Whether you’re an employee or a contractor:
a materiality assessment from the perspectives of our internal and • understand and follow our sustainability policies; and
external stakeholders. This assessment concentrates our efforts on
important current and emerging risks and opportunities and guides • apply the principles of sustainability to your
our public disclosures. day‑to‑day activities.

Reduce and mitigate potential impacts to the

environment or local communities through:
Examples of material topics we focus on to achieve
our vision includes: • carrying out regular risk assessments;
• Improving safety and health. • applying management plans that meet regulatory
requirements as a minimum and exceed them where
• Working with our communities. relevant;
• Responding to climate change. • putting in place safeguards to preserve and enhance
• Tailings management. our reputation as a sustainable company; and
• conducting reviews on the effectiveness of controls.
• Water management.
• Growth and financial sustainability. We also encourage you to identify and implement
• Respecting and protecting human rights. improvements that will increase sustainability where you
work. We talk about and inspire others to continue to
• Transparent and ethical business.
improve our sustainability.

We train our people in the principles of sustainability and we

encourage sustainable thinking by engaging with our people about
sustainability regularly.

Learn more Who to contact for help

Corporate Governance Statement Your line manager

Sustainability Policy Group Manager Sustainability and Social Performance

Climate Change Policy Head of Environment

Environmental Policy General Manager Environment, Sustainability and

Social Performance

Annual Sustainability Reports and
Annual Reports
We promote sustainability 57

In practice

Scenario Response

I injured myself at work but I don’t want to report it because No. Always report injuries and incidents so we can make sure
it’ll hurt my team’s good safety record. you get the right medical treatment.
Is this ok? We’ll also need to understand the cause of your injury
so that we can take action to prevent the injury from
happening again.
We want everyone to go home safe and healthy every day.
Improving the safety of our workplace is key to the
sustainability of our business.

At my site I feel our consultation with the local community We build long-term relationships based on mutual respect
is slowing us down. I think there could be restrictions put on and understanding. This is so we earn the trust and
our project. confidence of the communities where we operate.
Why does Newcrest place such a high priority on having A trusted community relationship is the foundation that
strong relationships with the community? allows us to operate. It’s key to the sustainability of our
business.
Shouldn’t our main goals be productivity and profit?
Disrespecting the community could lead to our customers,
suppliers and the governments that regulate us losing trust
in us – impacting our licence to operate.

We do We don’t

Balance economic, social and environmental issues in Disregard any element of sustainability – environmental, social
our business. or governance.

Take sustainability seriously. We follow all company policies. Participate in ‘green washing’. This is lying to get investors or the
community to think that a company is being responsible in its
Look for ways to increase our care for the environment as part care for the environment – when it’s not.
of our work. We discuss our ideas with our line manager.
Turn a blind eye if we become aware of a community complaint
Commit to achieving long-term sustainability goals. or concern. Any feedback that we get from the local community
needs to be passed onto our line manager.
Immediately stop work that could contribute to a significant
environmental or community incident, such as a spill, and Focus on short-term outcomes at the expense of long-term
speak up. sustainability goals.
58 Newcrest Code of Conduct

Climate Change
We are committed to the sustainable discovery,
development and production of gold and copper.

As a responsible miner we must identify, assess and report Our expectations of our people
our responses to challenges resulting from climate change.
We recognise that climate change is one of the most significant
challenges facing the world today. We acknowledge the climate To understand Newcrest’s Climate Change Policy
change science and support the Paris Agreement goals. and support its commitments, including:

Newcrest has committed to a 30% reduction in greenhouse gas • Identifying and managing climate change risks
emissions intensity by 2030 as well as a goal of Net Zero Carbon and opportunities.
emissions by 2050. We are committed to assessing our options • Partnering with technology developers as we
to increase use of renewable energy and low emissions energy transition to a low carbon future.
technologies.
• Partnering with experts and research partnerships to
We include Shadow Carbon Prices in our sensitivity analysis, identify potential physical threats from climate change
in the absence of jurisdictional carbon prices. A shadow carbon as well as adaptation and mitigation measures.
price provides a hypothetical cost of carbon to each tonne of
emitted CO2-e. It is used as a method to reveal hidden risks and
opportunities throughout our operations and supply chain. It will
also support strategic decision making as we consider future
capital investments.
We support the Task Force on Climate-related Financial
Disclosures (TCFD) Recommendations. Newcrest has taken
a phased approach to reporting against the TCFD framework
to make our climate-related risks and opportunities more
visible and transparent. Supporting the TCFD means increased
disclosures through our annual reporting, particularly through
our Sustainability Report and our Annual Report.

Learn more Who to contact for help

Climate Change Policy Your line manager

Sustainability Policy Group Manager Sustainability and Social Performance

Annual Sustainability Reports Manager Sustainability

Net Zero Carbon Emissions Program

Site Greenhouse Gas Management Plans


Site Greenhouse Gas Management
Plans example
We promote sustainability 59

In practice

Scenario Response

I’m interviewing applicants for a job in my team. This is a great opportunity to talk about our purpose of
creating a brighter future for people. This means we prioritise
Our preferred candidate asked me “what’s Newcrest’s
sustainable practices.
position on climate change?”
We recognise that climate change is one of the most
What do I tell her?
significant challenges facing the world today. We
acknowledge the climate change science and support
the Paris Agreement goals.
We have committed to a 30% reduction in greenhouse gas
emissions intensity by 2030 as well as a goal of Net Zero
Carbon emissions by 2050.

One of Newcrest’s customers has sent our team a Our customers are important external stakeholders and their
questionnaire as part of their supply chain review. questions and priorities are important to us.
One question is:
To answer the question, Newcrest is committed to assessing
“Does Newcrest invest in renewable energy and other options to increase our use of renewable energy and low
technologies?” emissions energy technologies. We’re also committed to
working with our suppliers and customers to reduce our
How do I answer?
Scope 3 emissions.

We do We don’t

Use resources efficiently. Waste resources.

Identify opportunities to reduce our energy use and greenhouse Deny climate science.
gas emissions wherever possible.
Ignore opportunities to recycle as much as possible.
Assess new mergers and acquisitions from a climate change
impact perspective. Ignore procedures that protect the environment.

Look for renewable energy opportunities. Minimise or downplay the importance of Newcrest’s
climate initiatives.
Work with our stakeholders to help address the causes and
impacts of climate change. Operate in isolation from our stakeholders, including
customers and suppliers.
60 Newcrest Code of Conduct

Key contacts and resources

Let’s use this Code of Conduct to keep

building a stronger Newcrest.

Living our values means we encourage open and honest

discussion about our Code of Conduct and how it applies to our
sites, projects and office workplaces.
If you have any questions about our Code of Conduct, talk to
your line manager, your local People Manager or your Ethics &
Compliance Champion. You can also raise issues of concern
through Newcrest’s various Speak Out channels.
Key contacts and resources 61

Key contacts

Speak Out channels

We provide a number of channels that you can use to make Other channels for making a Speak Out report
a Speak Out report, including an online and telephone internally include via:
reporting hotline. The hotline is secure and independently
1. Your line manager.
managed by a third party. To make a report via the hotline:
2. Speak Out app.
• Complete an online form at
www.newcrest.ethicspoint.com, or 3. The Speak Out Protection Officer at
• Use the free call number available in each of the following [email protected]
countries: or via mail at:
Speak Out Protection Officer

Your country Phone number to call
Level 8, 600 St Kilda Road
Australia 1800 812 608 Melbourne VIC 3004, Australia.
PNG +675 986 5030 4. A ‘Recipient’, identified in the Speak Out Policy which
includes the Board, ExCo, internal or external auditors.
Indonesia 001 801 10, then at the prompt in English
dial 855 867 7897
Canada 1 855 867 7897
USA 1 855 867 7897 Newcrest Ethics & Compliance Champions
You can contact our Ethics & Compliance Champions to
Fiji 00 1 855 867 7897
ask questions, get support, make a report or guide you
Chile Claro Chile – 800: dial 800 225 288, how and what channel to use.
then at the prompt in English
Email: [email protected]
dial 855 867 7897
Telefonica: dial 800 800 288, then at
the prompt in English dial 855 867 7897
Entel (English): dial 800 360 311,
then at the prompt in English
dial 855 867 7897 Chief Legal, Risk and Compliance Officer
Entel (Spanish): dial 800 360 312, You can contact our Chief Legal, Risk and Compliance Officer
then at the prompt in English to ask questions, get support or to make a report.
dial 855 867 7897
Ecuador For an English operator:
dial 1 800 225 528 then at the prompt
dial 855 867 7897
For a Spanish operator: The Legal Team
dial 1 999 119 then at the prompt in You can also contact members of our Corporate Legal Team who
English dial 855 867 7897 can help with legal questions and guide you as to the best avenue
for making a report.

Key resources
Newcrest website: www.newcrest.com
Links to Newcrest policies:
www.newcrest.com/about-newcrest/corporate-governance