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Code of Conduct PT Newmont Mining Corporation

Our Code of Business Ethics and Conduct ("Code") reaffirms the high standards of ethical business conduct required of all Newmont employees, officers and directors. Our Code has been adopted by Newmont's board of directors and constitutes Newmont's basic standards of ethical and legal behavior. Our Code supersedes the company's previous code of ethics and conduct.Acting with integrity, trust, respect, honesty and teamwork - all stated values of Newmont are principal characteristics of ethical behavior. For all of us, the basic requirement is that we conduct ourselves in a responsible manner, putting the company first in all our work-related decisions. While there is no substitute for common sense, our Code has been created to provide guidance to employees, officers and directors of Newmont on how to conduct the company's business, and to help identify critical issues that require caution and both ethical and legal consideration.Our Code also has been created as an educational and preventive tool - in part, designed to help prevent and detect violations of the law. In most circumstances, however, Newmont's standards are higher than the law requires. These expectations are further defined and more guidance is provided through our policies. Newmont has policies in most areas touched on in our Code including, but not limited to, workplace conduct and safety, securities trading, environmental protection, social responsibility and anticorruption measures. Adherence to these policies and our Code preserves the

confidence and support of the public and Newmont's stockholders.It is important to note, however, that our Code is not intended to provide specific answers to unique legal questions, to set forth a rule for every situation, to address all applicable laws or policies, to create legal rights or duties, or to set standards of conduct enforceable against Newmont.

Our Responsibilities

At Newmont, we live our values by being responsible and accountable for our actions. We are responsible for knowing and complying with the laws and policies that relate to our duties. Accountability Newmont holds each employee, officer and director, regardless of position or status, accountable for complying with Newmont's Code, policies, and all local and national laws in all countries in which we do business. Each of us also is obligated to comply with all other applicable laws, rules and regulations of any regulatory organization, licensing agency or professional association governing our professional activities. If you do not understand our Code, a policy, applicable laws or Newmont's expectations for your behavior, it is your responsibility to ask a manager, or contact the legal department or the compliance line to get clarification. All employees are accountable for reviewing our Code and certifying annually that they have done so. In addition, performance appraisals for all personnel include an evaluation of their demonstration of ethical behavior in compliance with our Code. Failure to live up to the responsibilities in our Code may result in disciplinary action being taken, up to and including termination of

employment. Additionally, because many provisions of our Code and Newmont's policies are based on legal requirements, violations may subject involved individuals and Newmont to criminal and civil penalties, including fines, jail sentences, and other criminal or civil sanctions. Additionally, managers are expected to lead by example. Managers must communicate our Code and relevant Newmont policies to their direct reports and help them understand these requirements. Managers must show respect toward employees and maintain open, honest and constructive two-way communications with them. This means not only allowing, but also encouraging employees to ask questions, make suggestions and report concerns or wrongdoing. Each manager should discuss Newmont's expectations for ethical conduct with his or her direct reports during the annual performance review process. Managers must assist in preventing violations of our Code, Newmont's policies and the law. When allegations of wrongdoing are brought to their attention, managers must escalate reports of alleged violations for investigation and cooperate with all investigatory actions, as well as any resulting corrective or disciplinary action Ways to Ask Questions and Voice Concerns When you have a question or concern, you can speak with your direct manager or supervisor, or talk to someone else in management, including a manager in the human resources department, as well as someone from a department who has the expertise and responsibility to address the concern. You also can contact the legal department or the internal audit department directly. Any of these people may have the information needed, or will be able to refer your question to another appropriate source. Another communication channel available to assist you is the compliance line. You can contact the compliance line when you have a concern or want to report a potential violation of our legal or ethical responsibilities. You can contact the compliance line anonymously. The compliance line, which is answered by a third-party vendor who is not an employee and does not office on any of our sites, is available to all employees,

24 hours a day, 7 days a week. The compliance line is not equipped with caller ID or other devices that can identify or trace the caller's number. Interpreters are available for language assistance. A Newmont employee will not be on your call.You may use whatever method of communication is comfortable for you. The important thing is to get the needed guidance, to report what is known and to get questions answered. Asking Questions and Voicing Concerns If any aspect of our Code is unclear, or if you have any questions or face dilemmas that is not addressed in our Code, you should bring these to your manager's or the legal department's attention. If you become aware of a situation in which you believe legal or ethical responsibilities are being violated, or if you feel that you are being pressured to violate the law or your ethical responsibilities, it is your personal responsibility to communicate this concern to management or the legal department.No employee will be disciplined, lose a job, or be retaliated against in any way for asking questions or voicing concerns about our legal or ethical obligations when acting in good faith. "Good faith" does not mean an individual has to be right, but it does mean the employee has to believe that the information provided is truthful. After a Concern is Raised When you raise a concern, you can expect that: * If you called the compliance line, your call will be assigned a tracking number and a report will be forwarded to appropriate management for follow-up. By calling back the compliance line and providing the tracking number, you can obtain follow-up information about the status of your report and how the concern was addressed. * Regardless of how you raise it, your concern will be handled discreetly and professionally. Discussions and inquiries will be kept in confidence to the extent appropriate or permitted by law. Your concern will be addressed by members of

management, which may include representatives from the legal department or the internal audit department. If the inquiry is one that can be properly handled by someone in the region, it will be referred there for resolution. Each concern will be carefully evaluated before it is referred for investigation or resolution. * Investigations into allegations of unethical or illegal conduct will be conducted professionally and to the extent possible, confidentially. All of us must cooperate in such investigations. Failure to cooperate in any such investigation shall be grounds for discipline, up to and including termination of employment. Protection Against Retaliation We have a responsibility to foster an environment that allows people to report violations or suspected violations without fear of retaliation or retribution. No one should be discouraged from using any available channel within the company. People must be able to choose whichever method they are most comfortable with to communicate their concern.Retaliation will not be tolerated at Newmont. Anyone who retaliates against another employee for reporting known or suspected violations of legal or ethical obligations is in violation of our Code and subject to disciplinary action, up to and including termination of employment. Retaliation also may be a violation of the law, and as such, could subject both the individual offender and Newmont to legal liability.If you suspect that you, or someone you know, has been retaliated against for raising a Code compliance issue, you should immediately report such allegation to the legal department or via the compliance line.

Our Commitment to Each Other

We recognize that our people are our most important asset and our performance as a company depends on respect for people. We recognize that our people are our most important asset and our performance as a company depends on respect for people.Our work force is dynamic and diverse, and we will treat each other with respect and dignity. As one of our values, we are committed to developing our people in the pursuit of excellence. We strive to provide a work environment in which we all are encouraged to share information, work as a team, take an active part in reaching our strategic goals and feel a sense of pride in working at Newmont. We further strive to recognize and reward creativity, a determination to excel and a commitment to action.Numerous laws and policies affect our work force. It is important that we comply with all applicable employment and labor laws within each country where Newmont operates. It also is important that we review and comply with the employment policies in place at a particular site. These laws and site-specific policies will provide more details on how we are to conduct ourselves, and what follows are some of the conduct standards. Equal Opportunity We recruit, select, place, promote and compensate employees on the basis of their qualifications for the work to be performed, including experience, merit and other work-related criteria. We consider workplace accommodations as appropriate to comply with all applicable laws governing fair employment and labor practices. We also support and obey laws everywhere we do business that prohibit discrimination on the basis of legally protected categories including, but not limited to, national origin, race, religion, sex, sexual orientation, disability and age, all as defined by the applicable law for each global work site. There are more specific equal employment policies at each site. Please refer to those policies for more detail on the topic. Anti-Harassment Our work environment will be free of illegal harassment based upon legally protected categories, as well as harassment in violation of site-specific

harassment policies. Please refer to site-specific policies for more detail to prohibit harassment. If you observe conduct that runs contrary to this principle, you have a responsibility to notify the human resources department or contact the compliance line. Workplace Safety We must use common sense and follow applicable safety laws, regulations and policies for the facility where we work. We must take the necessary precautions to prevent occupational illness or injuries. We are committed to working toward an injury-free workplace. We shall identify potential risks before accidents occur and integrate our safety management systems into the way we do business. If a task cannot be done safely, it will not be done at all. We must promptly report accidents and dangerous situations to our managers or the human resources department, as well as any and all applicable government agencies, as required by law.Further, we do not tolerate workplace violence of any kind. Newmont prohibits any act or threat of physical violence while conducting Newmont business, while on Newmont property, or while interacting with any Newmont employees, vendors or contractors. Examples of conduct that may constitute threats or acts of violence under our Code include: Threats or acts of physical or aggressive contact directed toward another individual or his or her family, friends, associates or property. The intentional destruction, defacing of, or threat of the defacing or destruction of Newmont property or another employee's property. Harassing or threatening phone calls or e-mails. Stalking. Veiled threats of physical harm or similar intimidation. Any conduct resulting in an arrest or conviction under any criminal law relating to violence or threats of violence. Prohibited Activities We do not tolerate illegal activity while on Newmont premises or while on Newmont business as it could put you, Newmont or others in harm's way. We will

comply with all laws and company policies. If, while on Newmont premises or while on Newmont business, you are engaging in activities contrary to law or policy, you will be subject to disciplinary action, up to and including termination of employment. The following illustrates activities that are against company policy and that will not be tolerated while you are on Newmont premises, in Newmont vehicles or on company business: Consumption and storage of alcoholic beverages at an operations or technical site, except when authorized by a member of senior management of the company and otherwise legally permitted. The unlawful manufacture, distribution, dispensation, possession, transfer, sale, purchase or usage of a controlled substance, such as illegal drugs. Driving vehicles or operating company equipment while under the influence of alcohol or controlled substances. Illegal betting or gambling. The possession of weapons of any sort, except by security or other personnel who are authorized by Newmont. Off-Duty Misconduct Our conduct that occurs away from Newmont property and outside of the normal course of Newmont business may also impact our company. Off-duty misconduct could jeopardize workplace safety or security, Newmont's image and reputation, or our ability to carry out our duties. Thus, we have an obligation to let Newmont know of our own off-duty misconduct as well as the off-duty misconduct of other employees.In the event you are charged with or convicted of a crime, whether related to our Code or not, you must report that fact to your manager and to the human resources department within five days of being charged or convicted.In addition, if you operate company motorized vehicles as part of your work assignments or are covered by a transportation authority's regulatory requirements, you have additional reporting requirements. Specifically, you must immediately report to your manager any on-the-job or off-the-job traffic ticket,

accident, citation or other issue that impacts the status of your driver's license.The impact of any off-duty misconduct on Newmont's interests will be assessed on a case-by-case basis. Newmont may, at our sole discretion and in accordance with applicable law, take disciplinary action, up to and including termination of employment.

Our Commitment to the Company

We recognize the trust and confidence placed in us by Newmont and must act with integrity and honesty in all situations to preserve that trust and confidence. Fraudulent or Dishonest Conduct Under no circumstances will we offer any false, fictitious or fraudulent information, report or claim to another person, or take unfair advantage of anyone through inappropriate manipulation, concealment, abuse of privileged

information, misrepresentation of material facts or any other similar practice. Any use of fraudulent or illegal tactics, including trespass on lands owned by others or the offering of bribes, is also prohibited. Participation in any such activity will subject you to discipline, up to and including termination of employment, and all such activity must be reported to the legal department or the internal audit department. Communications We will communicate with each other in a respectful, honest and transparent manner in accordance with our values. We will comply with our legal

obligations to keep shareholders, creditors, securities trading markets, suppliers and other stakeholders informed on a timely basis through regular public releases of relevant and understandable financial and other information about Newmont.The publication or circulation, either internally or externally, of any oral or written statement that is false, malicious or defamatory of any other person or company is prohibited.Further, Newmont is committed to treating personnel records and medical files with the same respect and confidentiality given to the company's records. Newmont will only collect, use and disclose employee information on a business need-to-know basis in conformance with applicable regulations or when required by law or court order. This policy also applies to former employees' information.Newmont has issued and will issue, from time to time, other policies with regard to communications, including the use of Newmont's electronic communications systems.As employees, officers and directors, we are expected to be familiar with and observe all such policies. Authority to Act on Newmonts Behalf Everyone has limitations on what he or she can do on behalf of Newmont. Most of these limitations are either limitations on binding the company or limitations on spending company funds. In short, we must not execute any contract or agreement on behalf of Newmont unless we are authorized by law to do so. (Typically, you must be an officer of the Newmont entity that is a party to that contract or agreement or hold a written power of attorney from an officer.) Also, we must not approve transactions or make commitments for Newmont funds unless the dollar amounts we are committing are within our authorized approval level, as specified in the executive authorities. If you need to clarify yours or another individual's authority to sign contracts or agreements or to commit Newmont funds, you should contact the legal department. Auditors Independence On a regular basis, outside auditors will review Newmont's financial information. We cannot take any action intended to improperly influence Newmont's auditors or the conduct of their audits.

Our Relationships

We will act responsibly, in accordance with our values and in a manner that will reflect favorably on us and Newmont. We must avoid conflicts of interest and other situations that are potentially harmful to Newmont when we deal with others. Gifts and Gratuities The giving and receiving of gifts and gratuities are commonplace in most societies. This practice in a business context is typically meant to create goodwill and establish trust in business relationships. However, in certain circumstances, the practice can create a conflict of interest or the appearance of impropriety. Thus, we must learn how to distinguish when to give and when not to give a gift, and when it is acceptable to receive a gift and when it is not acceptable. Avoiding Conflicts of Interest As employees, officers and directors, we must avoid situations where Newmont's interests and our own self-interest are or appear to be inconsistent. Newmont's business must be conducted solely for the best interests of the company, in an honest and ethical manner. No employee, officer or director, or a member of his or her family may, directly or indirectly, use his or her decisionmaking authority or position to receive any improper personal benefit from any sale, purchase or other activity of Newmont or in a way that is in his or her own interest, but not in Newmont's best interest

Our Commitment to Communities

We strive to engage and consult with communities and governments that host our operations and other stakeholders with respect, transparency and in accordance with the law.We remain steadfast in our commitment to sustainable partnerships, both at our operations around the world and through our corporate philanthropy program in Denver.We each have an obligation to the host communities in which we operate. We strive to be good stewards of the environment and socially responsible through our actions. Our goal is to engage with host communities and governments early in the development of a mine to begin to understand the respective community and share work with it to equitably manage the value created during the mine operation.We work with the mining sector, governments and host communities to monitor and work to prevent corruption. We will comply with all laws relating to our business abroad. Further, we are active participants and supporters of the Partnering Against Corruption Initiative (PACI). Finally, while competing in today's market, we assure that we do so in a fair manner that promotes competition. Acting with integrity when engaging with host governments and communities will assure that we uphold our values. Environmental and Social Responsibility Our strategy for managing the environmental and social aspects of our business focuses on the incorporation of environmental and social considerations into the full range of our operations' decision

Political Contributions and Activities Many countries have laws, including the U.S., both nationally and in each state, which prohibit or regulate contributions by companies to political parties or candidates. Complying with International Trade Laws In conducting our business, we will fully comply with all applicable U.S. laws governing imports, exports and the conduct of business with non-U.S. entities. Charitable Contributions Throughout the world, it is our goal to take part in projects to further the development and welfare of the local community. Assisting in the Fight Against Corruption Conduct that may be acceptable in the commercial business environment may not be acceptable in relations with government officials. Government officials play a special role in society. Competing in Todays World Generally speaking, the antitrust and competition laws of the United States and other countries forbid agreements or activities that restrain trade or limit competition and prohibit attempts to mon

Conclusion

While our Code sets forth the minimum standards of acceptable behavior, it is not intended to cover every issue that may arise. Your good judgment must always be your guide. Our Code is not solely what we may and may not do, it also is about providing us with resources to support us in doing the right thing. If you

need help deciding how to handle a particular situation at work, need to report a situation or need support in doing the right thing, the first person you should turn to is your manager. If you do not feel comfortable doing so, contact the compliance line, the legal department or another appropriate resource listed in our Code.While our Code sets forth the minimum standards of acceptable behavior, it is not intended to cover every issue that may arise. Your good judgment must always be your guide. Our Code is not solely what we may and may not do, it also is about providing us with resources to support us in doing the right thing. If you need help deciding how to handle a particular situation at work, need to report a situation or need support in doing the right thing, the first person you should turn to is your manager. If you do not feel comfortable doing so, contact the compliance line, the legal department or another appropriate resource listed in our Code. It is not always easy to answer this question and, in some circumstances, it can be extremely difficult to know what to do. When things are "grey," ask yourself: Are there any laws, regulations, policies or procedures that address this situation? What about the "spirit" of the law? Am I looking at this situation objectively or am I so emotionally involved that I should get help? What are the motivations of the others involved? How would I feel if my decision were featured on the front page of the newspaper? If made public, would my actions have the appearance of impropriety?

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