2021 Conflict-Free Gold Report

Newmont Corporation

June 30, 2022

INTRODUCTION

Achieving Newmont Corporation's ("Newmont") purpose to create value and improve lives through sustainable and responsible mining requires us to demonstrate that our gold has been extracted in a manner that does not cause, support or benefit unlawful armed conflict or contribute to serious human rights abuses or breaches of international humanitarian law. Newmont takes this responsibility seriously and has implemented the World Gold Council's Conflict-Free Gold Standard (the "Standard") since 2013. Our commitment to the Standard is available on our website. This Conflict-Free Gold Report summarizes how Newmont conforms to the requirements of the Standard for the year ended 31 December 2021. The Executive Vice President and Chief Sustainability & External Affairs Officer is responsible for implementation, and reports to the Chief Executive Officer as well as the Safety and Sustainability Committee of the Board of Directors, which has ultimate responsibility for Newmont's compliance.

REPORTING BOUNDARY

The reporting boundary of this Conflict-Free Gold Report includes all mining and processing operations over which Newmont had 50% or more control in the calendar year ended 2021. This is consistent with the reporting boundaries that Newmont publicly discloses in its 2021 Annual Sustainability Report. A link to the reporting boundaries, along with a comprehensive list of Newmont operations included in the reporting boundary is provided in Attachment A.

References to "Newmont," "the Company," "we" and "our" refer to Newmont Corporation (formerly Newmont Goldcorp Corporation and Newmont Mining Corporation) and/or our affiliates, joint ventures and subsidiaries.

NEWMONT'S EVALUATION

PART A - CONFLICT ASSESSMENT

In order to evaluate Part A of the Standard, Newmont conducted a review of the international sanctions as listed in Attachment B to assess whether international sanctions have been imposed on the countries in which we have mines. We concluded that no applicable international sanctions have been imposed on the countries in which we had mining operations during the year ended December 31, 2021.

As part of the Conflict Assessment evaluation, Newmont also reviewed the Conflict Barometers published by the Heidelberg Institute for International Conflict Research to determine whether the area(s) in which our mines are located are classified as "conflict affected or high risk." According to the Heidelberg Conflict Barometer, out of the countries in which Newmont has mining operations, Mexico was the only one ranked 4 (limited war) on a national level because of drug cartel activities. According to the same source, the Zacatecas state in which Newmont's Peñasquito mine is located

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does not exceed a level 3-violent crisis. Despite this, in an effort to be transparent about its practices and ensure full compliance with the Standard, Newmont undertook assessments of Parts B through E as set out in the Standard for this one operation. Additionally, two product receiving countries ranked 4 (limited war), South Africa and the Philippines, which are the final destination countries for our Musselwhite and Boddington sites respectively. The remaining sections of the Standard do not apply to Newmont's other sites.

PART B - COMPANY ASSESSMENT

Part B of the Standard assesses whether the company has the appropriate systems in place in order to discharge its corporate obligations and responsibilities, to avoid causing, supporting or benefiting unlawful armed conflict, or contributing to serious human rights abuses or breaches of international humanitarian law. In order to meet the requirements of Part B of the Standard, Newmont evaluated whether its policies, processes and procedures were adequate to ensure conformance with the Standard for the Peñasquito mine in Mexico. Based on the supporting evidence below, which includes examples of Newmont's commitments and practices, Newmont concluded that it is in conformance with the Standard:

Commitment to respecting human rights

  • Outlined in ourSustainability and Stakeholder Engagement Policyand operationalized through ourHuman Rights Standard
  • Activities to mitigate Modern Slavery risks are detailed in ourStatementand further detailed in our human rights program provided in our Guide

Risk Management

  • Country risk program analyzes the socio-political risks across the countries of interest to Newmont.
  • Newmont's new Geopolitical Risk Program (GRP) includes qualitative and quantitative risk ratings and access to near real-time global risk intelligence data through an external platform. The GRP has been integrated with the company's overarching Risk Management
    System to ensure Enterprise level political risks are recorded in the risk and event reporting platform and critical controls are developed and monitored.
  • Quarterly external geopolitical risk reports will quantify and assess risks where Newmont operates (including security risks) to inform risk management and strategic decisions.
  • Mexico specific risks are managed and reported at all levels of the company. Controls in place range from several cross-functional committees where key functions analyze sociopolitical, security, and communications issues to strategies that outlines detailed management plans for identified risks.
  • Updates are provided to the Board's Safety and Sustainability Committee and Newmont's North American leadership team reviews the country's most salient issues (including government relations and security) that require management attention. A number of other

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Steering Committees involving country and executive leadership exist to manage particular issues, including security.

  • In addition to internal monitoring efforts, external risks in Mexico are monitored by two political risk consultants who advise the company on emerging trends and how the company could be impacted. Recommendations related to risks in Zacatecas are provided and, in 2021, these included recommendations around security measures during transfers by land.

Security

  • Implementation of the Voluntary Principles on Security and Human Rights ("VPs") as outlined in ourannual reportto the VPs plenary
  • Formation of a cross-functional group (including External Relations, Legal and Security) in Mexico to monitor risks, including those associated with corruption and money laundering and to put in place appropriate controls with suppliers and clients.
  • Monthly Key Performance Indicators for Private security contractor in Mexico linked to the VPs.
  • Enhanced tracking of training of security guards in Mexico including evaluations and drills.

Payments and benefits-in-kind

  • Through ourCode of Conductand Business Integrity Policy, as well as our membership in Partnering Against Corruption Initiative, we outline our commitments to integrity and doing business in a responsible way wherever we operate, including the minimum requirements for effectively managing the risks associated with government payments. Newmont provides online and in-person training opportunities for employees on these commitments, including to employees who have decision-making authority related to payments and in-kind donations.
  • Our Conflict of Interest Standard currently requires employees to disclose all actual or potential conflicts of interest via an online platform once they join the Company and when there is a change in their roles. Currently we are in the process of updating the Conflict of Interest Standard to require disclosures based on the risk exposure of the employees.
  • Our Anti-Corruption Standard has requirements around prohibiting government payments and improperly influencing government officials, as well as establishing different levels of approvals for providing anything of value to a government official.
  • Our Gift Registry tracks gifts and entertainment crossing established thresholds received from and given to third parties including government officials.
  • We commit to theExtractives Industries Transparency Initiative("EITI") and support its implementation in countries where we operate.

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  • We publicly disclose payments to governments in ourAnnual Sustainability Reportand in our Extractive Sector Transparency Measures Act (ESTMA) report. In complying with ESTMA reporting requirements, we disclose specific in-kind and cash donations to government entities. These reporting initiatives will continue in the future, and will include all countries where Newmont sites are located.
  • Our Global Business Integrity & Compliance program promotes a culture of integrity and personal accountability through providing information and tools, including training, to identify, evaluate, address and resolve situations in which potential ethical misconduct is involved.
  • To comply with Section 302 of the Sarbanes-Oxley Act (SOX 302), specified senior business leaders provide quarterly certifications that respective regions maintained effective controls and they are not aware of any interaction or payment by Newmont, or on Newmont's behalf, that would violate our Code, policies, standards or applicable laws.
  • All third-parties such as beneficiaries of donations and commercial vendors are screened against key sanctions (including US and United Nations sanctions) at the time they were engaged with Newmont.

Engagement, complaints and grievances

  • OurStakeholder Relationship Management Standardoutlines the requirements for all sites to adequately identify and effectively engage local communities and have appropriate complaints and grievance mechanisms in place
  • TheIntegrity Helplinesupports the identification of issues in breach of our commitments. The Helpline supports reporting in all Newmont working languages as well as most other global languages.
  • Site level complaints and grievances mechanisms and registers are required at all sites to address external stakeholder concerns in a timely and effective manner

PART C - COMMODITY ASSESSMENT

Part C of the Standard assesses the processes in place to manage the movement of gold and gold- bearing material while in the custody of the company, so as to mitigate against the misuse of this material by groups associated with unlawful armed conflict. Newmont puts in place strict controls to ensure no materials are misappropriated in transit. In Mexico, these include GPS tracking on the armored trucks used for transporting material from the mine to the Port and weighted truck beds. Weights are recorded and reconciled during each leg of transportation including mine site, port facilities, and receipt at smelter. In addition, intelligence work is undertaken on the providers who transport the materials from the mine and for the transportation routes. The intelligence identifies any issues on the route (including road blocks) and evaluates the security of alternative routes.

South Africa is the final destination for Musselwhite mine's carbon fines (which is rated as a 4, limited war, on the Heidelberg Conflict Barometer). Newmont's risk of loss to the carbon fines transfers to the buyer at the Musselwhite mine gate. The title to the carbon fines passes to the

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buyer upon the receipt of the buyer's provisional payment, which occurs a few days after pick up from the mine gate in Ontario, Canada. Given this, South Africa is considered out of scope for this section of the Standard.

The Philippines is the final destination for Boddington's copper concentrates (which is also rated as a 4, limited war, on the Heidelberg Conflict Barometer). Newmont's risk of loss to this product transfers upon loading the concentrates into the vessel at the port of Bunbury, Australia and title passes upon receipt of the shipping documents (bill of lading), which occurs a few days after the loading of the material and prior to material's arrival in the Philippines. Given this, the Philippines is considered out of scope for this section of the Standard.

PART D - EXTERNALLY SOURCED GOLD ASSESSMENT

All sites were reviewed to determine if they source gold or gold-bearing material from external suppliers. The table below details that none of Newmont's mines were found to source gold from external suppliers.

DOCUMENT/SOURCE TITLE

DOCUMENT AUTHOR

PURPOSE

Newmont internal Conflict-Free Gold Assessment

Newmont

Confirmation from

forms and supporting documentation (shipping

each site that there

manifests, bills of lading, shipper contracts and

has been no

related evidence) signed and certified by regional

externally sourced

leadership, provided to external assurance

gold

provider for review.

PART E - MANAGEMENT STATEMENT OF CONFORMANCE

Newmont Corporation confirms, to the best of its knowledge, that the gold produced by Newmont- operated mines in the United States (CC&V), Peru (Yanacocha), Suriname (Merian), Ghana (Ahafo and Akyem), Canada (Éléonore, Musselwhite and Porcupine), Argentina (Cerro Negro), Mexico (Peñasquito), and Australia (Boddington and Tanami) does not, in any way, contribute to armed conflict or human rights abuses or breaches of international humanitarian law.

Newmont Corporation confirms, to the best of its knowledge, that the gold produced by Newmont- operated mines at CC&V in the United States, Yanacocha in Peru, Merian in Suriname, Ahafo and Akyem in Ghana, Éléonore, Musselwhite and Porcupine in Canada, Cerro Negro in Argentina, Peñasquito in Mexico, and Boddington and Tanami in Australia do not, in any way, contribute to armed conflict or human rights abuses or breaches of international humanitarian law.

The mining operations covered in this report have the appropriate systems and controls in place to conform to the World Gold Council's Conflict-Free Gold Standard and the company's Conflict-Free Gold report for 2021 was subject to independent assurance.

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Newmont Corporation published this content on 01 July 2022 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 01 July 2022 21:22:01 UTC.