OUR PEOPLE

We are united by our purpose and values. These are the foundation for our Code.

Our code of business conduct sets the standards we expect of our people (Directors, executive management, employees and contractor staff), our suppliers and our joint venture partners acting on our behalf in a controlled or operated joint venture. It also represents our commitment to act ethically, responsibly and lawfully. We view a breach of our Code as a serious matter that must be addressed.

Speaking Up protects everyone. We encourage all our people to speak up when our values and conduct standards are not being followed.

Our Code outlines the options for reporting a business conduct concern, which includes our confidential reporting hotline. Anyone can openly or anonymously report a business conduct concern. All reports received via our hotline are confidentially sent to Senior Executives to assess and respond to appropriately in accordance with our Speak Up processes.

We do not tolerate any form of retaliation against anyone for reporting a business conduct concern. We inform our Risk and Audit Committee and Board of material business conduct concerns, and material breaches of our Code.

We prohibit fraud, bribery and corruption in any form, and comply with applicable anti-bribery and corruption laws wherever we conduct business.

We believe that through the fair allocation of resources, we create value and can make a difference to the communities where we operate. If corruption is not appropriately addressed, it negatively impacts the lives of people in our host communities by:

■ Depriving them of needed benefits;

■ Driving up the costs of public services and works;

■ Misallocating resources;

■ Wasting opportunities that arise from resource development; and

■ Undermining the integrity of governments, through the improper influencing of government decision-making.

As part of our commitment to act ethically, responsibly and lawfully, we operate a risk-based anti-bribery and corruption (ABC) compliance program which our Board, CEO and Managers have approved.

Our ABC compliance program:

■ Includes performing ABC risk assessments. These risk assessments form a critical part of our ABC compliance program, allowing us to focus our resources on the highest risk areas and ensuring we adopt adequate controls to mitigate these risks;

■ Focuses particular attention on third-party representatives who interact with government officials on our behalf. Our Code contains our anti-corruption expectations available to everyone, including our third parties who represent us (i.e. who we call our “business partners”). Our Code is supplemented by additional internal ABC requirements in related standards and procedures. We have processes requiring our Business Integrity team to pre-clear certain of our business partners before they are engaged. In addition, we include suitable ABC clauses in our standard contracts with such third-party representatives;

■ Requires pre-approval from our Business Integrity team to:

• offer, give or receive (above modest value) gifts, entertainment and/or hospitality;
• offer or give community and charitable contributions, and sponsorships;
• attend any paid political event or activity; and
• offer or give any other thing of value on our behalf;

■ Encourages our people to speak up and report ABC concerns; and

■ Includes ABC training for identified employees at higher risk of exposure to corruption.

Our Code, supplemented by internal procedures, set out our expectations and requirements about avoiding, declaring and managing conflicts of interest.

As part of our conflict resolution process, all actual, potential or perceived conflicts of interest need to be entered in our Conflict of Interest Register.

Directors who have a material personal interest in a matter that is being considered at a meeting of Directors are prevented from accessing relevant Board papers or taking part in related discussions. The other Directors may allow such Directors to participate and vote in relation to the issue only if they are satisfied that the interest should not disqualify the Directors from voting or being present.