African Barrick Gold (ABG) MINE INVESTIGATIONS GROUP ...

African Barrick Gold (ABG)

MINE INVESTIGATIONS GROUP

Investigations policy

APPROVED BY:

General Counsel:

Vice President: Security & Crisis Management (Barrick Gold Corporation):

May 2010

Confidentiality: Confidential and © Doc No. Version: Issue Version 1

Title: Investigations Policy ABG of 36 Version Date: May 10, 2010

Document Controller: Cassie Boggs

1 PURPOSE ........•..................•...........•.....•........•............................. 7 2 SCOPE ...............•.........••..........•...•.............................................. 7 3 GLOSSARY OF TERMS ...................•............•.............................. 7

3.1 Case File .............................................................................................................. 7 3.2 Exception Report .... : ........................................................................................... 7 3.3 Informant. .............................................................................................. '" ........... 7 3.4 Investigations ....................................................................................................... 7 3.5 Offence ................................................................................................................ 8 3.6 Product ................................................................................................................ 8 3.7 Record of Interview ............................................................................................ 8 3.8 Investigation Records .......................................................................................... 8

4 Roles and responsibilities ......................................................... 8 4.1 Manager - Investigations ................................................................... : ................. 8 4.2 Investigations Superintendents ........................................................................... 9 4.3 Site Security Managers ....................................................................................... 9

5 Types of investigations ..•..................................................... a •••• 9 5.1 Category A investigations (FATALITY & SERIOUS INJURIES) ................... 9

5.1.1 Reporting for Category A investigations .................................................... 9 5.1.2 Specific Requirements .............................................................................. 10

5.2 Category B Investigations ................................................................................. 11 5.2.1 Reporting for Category B investigations .................................................. 11 5.2.2 Specific requirements ................................................................................ 12

5.3 Category C Investigations ................................................................................. 13 5.3.1 Reporting for Category C investigations .................................................. 13 5.3.2 Specific requirements ................................................................................ 14

5.4 Category D Investigations ................................................................................. 14 5.5 Category E investigations ................................................................................ 14

5.5.1 Reporting for Category D and E investigations ....................................... 14 5.5.2 Specific requirements for Categories D and E .......................................... 15

5.6 Specific Requirements for Investigations - Fatalities, Product Theft, Illegal Miner fatalities, Weapons Discharge .................................................................. ~ ......... 15

5.6.1 Deaths of employees, contractors or any visitor on the SML ................... 15 5.6.2 Special requirements: ................................................................................ 15

5.7 Injuries/deaths to illegal miners or detainees .................................................... 16 5.7.1 Specific requirements ................................................................................ 16

5.8 Product theft investigations ............................................................................... 18 5.8.1 Specific requirements ................................................................................ 18

5.9 Weapons discharge investigations (To be read in conjunction with Barrick Security Procedure For the Use of Force - Part 4) ....................................................... 18

5.9.1 Specific requirements for lethal ammunition discharges; ......................... 18

6 Incident scene attendance and examination ......................... 19 6.1 Establish if the scene is a "Police Crime Scene" or "Non Police Crime Scene"

19


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Version Date: May 10, 2010 Document Controller: Cassie Boggs

6.2 Secure the scene ................................................................................................ 19 6.3 Safety assessment .............................................................................................. 19 6.4 Manage the scene .............................................................................................. 20 6.5 Identify the evidence ......................................................................................... 20 6.6 Record the scene ....................................... ~ ....................................................... 20 6.7 Gather the evidence ........................................................................................... 20 6.8 Return the scene to owner or normal operations .............................................. 20 6.9 Recording investigations on Secure Base ......................................................... 20

7 Case file management ............................................................. 21 7.1 Documentation within case files ....................................................................... 21

8 Allocation of investigations .................................................... 22 9 Handover of investigations ...................................................... 22 10 Interviews ............................................................................. 22

10.1 Witness interviews ............................................................................................ 23 10.2 Category A Witness statements: ....................................................................... 24 10.3 Category B - E Witness statements; .................................................................. 24 10.4 Suspect interviews ............................................................................................ 25 10.5 Records of Interview ......................................................................................... 26

10.5.1 Introduction ............................................................................................... 26 10.5.2 Body .......................................................................................................... 26 10.5.3 End ............................................................................................................ 26 10.5.4 Manner of conducting interview ............................................................... 27

10.6 Report writing ......................................................... : ......................................... 27

11 Periodic reporting ................................................................. 28 12 Prioritization principles for tasking(s) ................................. 28

12.1 General approach ............................................................................................... 28 12.l.l Urgent cases - Category A & B Investigations ........................................ 28 12.1.2 Non urgent cases - Category C- E Investigations .................................... 28

12.2 Competing interests and multiple cases ............................................................ 28 12.3 Delays ............................................................................................................... 29

13 Confidential Informant Management ................................... 29 13.1 ABG Confidential Informant Management Policy ........................................... 29

14 Surveillance Exception Reports & Relationship to Surveillance Units ...........................•..........................•..•...........••... 29

14.1

15 Product from Surveillance Unit .............................................. ~ ......................... 29

Exhibit Handling •••..••...••••..••..•••.•••.•••••••••..•...•...•.••.•..•.•....•...• 30 16 Oversight functions ..............................•............................... 30

16.1 16.2 16.3 16.4

17 18

Arrests and detention ........................................................................................ 30 Injuries caused by or during Security operations ................... : .......................... 31 Weapons use ..................................................................................................... 31 Policy & Procedures ......................................................................................... 32

Training within Security Department .................................. 33 Preventative strategies .•...........••.....••••..••.................. P ••••••••• 33

Confidentiality: Confidential and © Doc No. of 36

Title: Investigations Policy ABG Version Date: May 10, 2010

Document Controller: Cassie Boggs Version: Issue Version 1

19 Targeted investigations ........................................................ 34 20 Confidentiality ..................................................... 11 •••••••••••••• a •• 34 21 Police and Courts ................................ a •••••••••••••••••••••••••••••••• 34

21.1 General ......................................................................................... ' ..................... 34 21.2 Process serving and execution .......................................................................... 35

22 Court files ................................................................................ 35 22.1 Crime reports and arrests .................................................................................. 35

23 Records Management ........................................................... 35 24 References ....................................•....................................... 36




DISTRIBUTION LIST

COPY No 1 2 3 4 5 6 7 8 9 10 11 12 13 14


ISSUED TO DATE ISSUED General Counsel

Group Security Man,![er Secur~ O~erations Man~er

Investigations Manager Investigations Operations Manager Investigations S~erintendent MIG Investigations Coordinator Buzwagi

Investigations Coordinator Bulyanhulu Investigations Coordinator North Mara Investigations Coordinator Tulawaka

Security Manager Buzwagi Security Manager Bulyanhulu Securik Man~er North Mara Security Manager Tulawaka



DOCUMENT CONTROL RECORD

The re-issues of this document, listed below, have been reviewed and approved by Management and are authorized for use within the African Barrick Gold organization.

DOCUMENT CONTROL BLOCK

Rev No Page Nos Details of Issue


of 36

Authorization Name Signature

Title: Investigations Policy ABG Version Date: May 10, 2010

Document Controller: Cassie Boggs

Date

1 PURPOSE

To describe the processes and protocols used by members of the Mine Investigations Group (MIG) when carrying out their duties.

2 SCOPE

This policy applies to members of the MIG.

3 GLOSSARY OF TERMS

3.1 Case File

Means the (original) physical items derived during an investigation and shall (where practical) be kept together within a folder and securely stored by the MIG. Case files are individually and uniquely numbered and include a site identifier.

3.2 Exception Report

Means a report generated via the SecureBase database outlining details of a suspected breach of ABG policy or procedures, a breach of safety, a breach of security, or other matter requiring an action to be reviewed by the MIG.

3.3 Informant

Means a person, (other than an employee of the Security Department), who provides confidential or sensitive information to the MIG that is, or may be, used in an investigation.

3.4 Investigations

Means a process that complies with the following basic outline as a minimum;

a) Receive or develop complaint b) Establish that an Offence has been committed, or is being planned to be

committed c) Identify the area(s) of legislation and/or policy that have, or may have

been breached d) Establish what particular elements of the Offence(s) are needed to prove

an Offence(s) e) Identify all witnesses or potential witnesses to the Offence{s) f) Identify the persons involved in committing the Offence(s)




g) Identify a" types of evidence available that prove or assist in proving the Offence{s) or that disproves the Offence

h) Gather, record and preserve all available evidence i) Interview a" available witnesses and persons of interest i) Review all evidence available and make a determination as to the best

course of action to resolve matter j) Prepare reports and files for forwarding and review by relevant competent

authorities k) Manage the prosecution process to completion I) At all times comply with the requirements of relevant legislation, ABG

Policy and Procedures, and ABG Code of Conduct

3.5 Offence

Means a breach or contravention of ABG policy Qr any applicable law, statute, policy, code or standard. .

3.6 Product

Means any gold bearing material other than unprocessed or untreated ore mined within the lease areas of a ABG operation or project.

3.7 Record of Interview

Means a written document OR electronica"y recorded interview complying with the requirements of the relevant Tanzanian legislation, and that records a" of the conversation between an investigator and person who may have breached legislation or internal procedures or policy. It is conducted in a formal manner to demonstrate transparency and to show all the questions that were asked and a" of the answers that were given.

3.8 Investigation Records

Means the case file, exhibits, electronic documents or entries (ie entries into Securebase) and any other documents or records generated as part of an investigation or otherwise under this Policy.

4 Roles and responsibilities

4.1 Manager -Investigations

Is responsible for ensuring a" members of the MIG are aware of and comply with their duties and responsibilities, and that they carry out their function in accordance with this policy.


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Is responsible for setting priorities based upon the MIG's mandate and the Matrix for Investigations.

4.2 Investigations Superintendents

Are responsible for ensuring that all investigations undertaken by the Mine Investigations Group are compliant with the spirit and intention of this policy.

4.3 Site Security Managers

Are responsible for ensuring all matters requiring investigation are reported to the Manager - Investigations.

5 Types of investigations

The types of investigations are set out in the Security Investigations Matrix, and are identified as Categories A - E.

These investigations may be instigated at the direction of Office of General Counsel (OGC), Chief Operating Officer, Group Security Manager, or Manager -Investigations.

5.1 Category A investigations (FATALITY & SERIOUS INJURIES)

Category A investigation includes the following types of investigations:

• The death of a person within building or land owned, leased or controlled by ABG, or

• The death of a person involving an employee of ABG, or • The death of a person involving an asset of ABG, or; • Multiple serious injuries • Use of hard munitions by ABG personnel or contractors • Involving theft of dore and concentrate • Involving theft of USD 100,000 or more • Serious investigation directed by the Office of General Counsel • Material Violations of Policy and Procedures, including corruption of, or by,

senior ABG employees or major contractors;

5.1.1 Reporting for Category A investigations

The reporting/notification requirements of the following instructions must be complied with:




1. Fatality/High Potential Notification protocol 2. ABG Code of Conduct, Anti-Fraud Policy and Escalation Policy

For matters not falling within the reporting of points 1 and 2 above the following persons shall be notified:

• Site General Manager, • Manager - Investigations • Group Security Manager • The Regional Legal Counsel • Office of General Counsel • Chief Operating Officer

Any fatalities must also be reported in accordance with the Notification Plan (Fatality Incidents), which requires notification to be given by the General Manager to the Chief Operating Officer, Group Safety Manager, Office of General Counsel and the Manager - Investigations within 2 hours of incident. The flash report forms are annexed to this Policy.

5.1.2 Specific Requirements

All Category A investigations MUST be conducted in accordance with the directions of the Office of General Counsel (OCG).

A detailed running sheet is to be typed which provides a precise account of the entire investigation, including details of statements taken, all avenues of investigations undertaken and follow up inquiries that require completion.

All Category A investigations are to be conducted pursuant to a written 'scope of investigation' provided by the OCG outlining the manner in which such investigation is to be conducted, and unless otherwise advised by the OGC , will be undertaken for the dominant purposes of obtaining legal advice andlor preparing for legal proceedings for prosecutions for and on behalf of ABG.

The reports will be distributed as directed by the Office of General Counsel in the scope of investigation and should be clearly labeled" Confidential and Privilegedthis document is produced for the dominant purpose of seeking legal advice and for use in litigation". THE REPORT IS NOT TO BE SENT TO ANY OTHER PERSON other than those identified in the scope of investigation.

The logging of these investigations in SecureBase should be limited to name, date, basic factual description (taken from the Flash report), and refer to the OCG investigation. A case number should be allocated. Following completion of the investigation, the Investigation Records should be sent as directed by the




OGC and a note made in SecureBase as to the date, method and recipient of the Investigation Records.

5;2 Category B Investigations

Note: The requirements of the ABG Code of Conduct, Anti-Fraud Policy and Escalation Policy remain in place

A Category B investigation includes, but is not limited to, an investigation into allegations of Offence(s) that;

• Involves theft, fraud or damage of assets worth between USD $25,000 -100,000

• involve organized criminal conduct against the ABG by a group or two or more persons, whether they are employees or not;

• or • involve serious and ongoing breaches of criminal law that have a cost to

ABG of over USD $25,000.000 or have the potential to have significantly negative impact to the reputation of ABG; or

• involve a serious violations of Policy and Procedures and of the Disciplinary Code; or

• involve a serious injury, serious breach of safety or a near miss with a high potential rating; or

• involve a member of the Security Department allegedly involved in criminal offences or serious breaches 'of policy and procedures; or

• Involving a weapons discharge investigation and includes but is not limited to

• Excess Use of Force by any ABG Security Officer or Security Contractor, • Any Use of Force employed where Policy or Procedure are believed to be

in breach, • The loss or theft of any Use of Force Option or munitions, • Any incident involving the Use of Force which may have a negative

impact, or damage the reputation of ABG, • Any other incident involving a Use of Force option deemed worthy of

investigation by the Manager - Investigations or his/her delegate.

5.2.1 Reporting for Category B investigations




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• Site General Manager • Site Security Manager • Regional Legal Counsel • General Counsel • Group Security Manager • Manager - Investigations

The Country Legal Counselor delegate may give directions as to the conduct of the investigation. In this case, the investigation must be conducted in accordance with the scope of investigation. In these circumstances the investigation report should be prepared in accordance with the direction of the Country Legal Counsel and the investigation report must be forwarded to the Country Legal Counsel and General Counsel and no other person. The logging of these investigations in SecureBase should be limited to name, date, basic factual description (taken from the Flash report), and refer to the OCG investigation. A case number should be allocated. Following completion of the investigation, the Investigation Records should be sent as directed by the OGC and a note made in SecureBase as to the date, method and recipient of the Investigation Records.

All other reports relating to Category B investigations (other than investigations undertaken pursuant to an instruction from Country Legal Counsel) must be forwarded to the Site Security Manager and General Manager.

5.2.2 Specific requirements

• Must comply with the minimum standards prescribed in the definition of Investigations in Section 3.

• Case File must be created, complying with definition provided in Section 3. • Must assess the existing security measures, policy and procedures, to

establish whether they are adequate • Must advise the Regional Security Manager if there any identified

breaches or deviations from existing security measures or policy and procedures

• Investigators MUST provide all assistance and information required by any external review team sent to site from Corporate Office e.g. Safety experts, auditors and other investigators working on behalf of ABG General Counsel.

• Personnel involved in any discharge of force incident must undergo a Drug and Alcohol test with two (2) hours of the incident (Section 4.9.2 (d) ABG Security Procedure For the Use of Force)




5.3 Category C Investigations




• Site General Manager • Site Security Manager • Regional Legal Counsel • General Counsel • Group Security Manager • Manager - Investigations

A Category C investigation includes, but is not limited to, an investigation into allegations of Offence(s) that;

• Fraud, theft or damage to assets of between USD $10,000 - 25,000 • Theft of gold bearing ore • Trespassers • Multiple minor injuries • Use of soft munitions or gas by Barrick personnel or contractors • General violations or infractions of policy or procedures

5.3.1 Reporting for Category C investigations

All Category C investigations must be reported to:

• Site Security Manager • Site General Manager • Country Legal Counsel • Regional General Counsel • Regional Security Manager • Regional Investigations Manager

All other reports relating to Category B investigations (other than investigations undertaken pursuant to an instruction from Country Legal Counsel) must be forwarded to the Site Security Manager and General Manager


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• Must comply with the minimum standards prescribed in the definition of Investigations in Section 3.

• Case File must be created, complying with definition provided in Section 3. • Must assess the existing security measures, policy and procedures, to

establish whether they are adequate • Must advise the Regional Security Manager if there any identified

breaches or deviations from existing security measures or policy and procedures

• Investigators MUST provide all assistance and information required by any external review team sent to site from Corporate Office e.g. Safety experts, auditors and other investigators working on behalf of ABG General Counsel.

5.4 Category 0 Investigations

A Category D investigation is any investigation involving:

• Theft damage or fraud of assets under $10,000 • Minor injuries • Minor breaches of Policy and Procedures

5.5 Category E investigations

A Category E investigation is any investigation not covered under Category A, B, C, or D and includes, but is not limited to;

• Theft of assets under US$1000 • Minor breaches of disciplinary matters that should be dealt with by Head

of the Department of the employee involved. • Matters deemed by the Regional Investigations Manager to be Category E • Uncorroborated allegations • Minor Offences that are not likely to be solved as there are no witnesses

or known suspects.

5.5.1 Reporting for Category 0 and E investigations

All other reports relating to Category D & E investigations (other than investigations undertaken pursuant to an instruction from Country Legal Counsel) must be forwarded to the Site Security Manager and General Manager.

In relation to investigations where no suspects can be identified and there is no likelihood of any person every being dealt with over this matter, all actions are to




be recorded on secure base. An investigation report is not required and the file can be completed on Securebase.

5.5.2 Specific requirements for Categories D and E

• All actions must be recorded on secure base. • Must be a case file as described at 3.1. if statements have been obtained

or any other investigative material is to be stored with the file. • Must assess the controls in place to prevent the issue (if any) from

occurring • Must address the case specific issues and make relevant

recommendations to prevent recurrence or improve business performance and/or safety.

5.6 Specific Requirements for Investigations - Fatalities, Product Theft, Illegal Miner fatalities, Weapons Discharge

5.6.1 Deaths of employees, contractors or any visitor on the SML

The death of any ABG employee, contractor, visitor or any other person within the SML will at all times be treated as a Category A investigation. Unless otherwise directed by OGC, the guidelines for Category A investigations MUST be followed .

5.6.2 Special requirements:

• The Manager - Investigations MUST be informed of all deaths on site. • The Site Security Manager and a member of MIG MUST attend all deaths

on site. • All deaths on SML MUST be reported to as soon as possible to the

Tanzania Police Force by the Manager -Investigations or an Investigator delegated to perform this task. .

• The scene where the death occurred must be secured and treated as a police crime scene. The only time that the scene can be entered or interfered with is to preserve evidence that may be lost or destroyed before the police arrive or if the police do not attend within a reasonable period of time.

• The Manager - Investigations MUST obtain confirmation that the death has been reported to the Tanzania Police Force and a record MUST be kept of the police station occurrence book entry number which will be kept with the investigation file.

• The MIG will ensure that a trained site medical technician attends the scene, with the site ambulance or other applicable vehicle to examine the deceased and confirm death.




• The MIG must ensure that under no circumstances does a ABG employee interfere with the body of the deceased.

• The MIG MUST ensure the body of any person found to be life extinct by trained site medical technicians is taken to the nearest Hospital Morgue.

• Under no circumstances is the deceased person to be conveyed to the Mine Site Medical Centre.(To be read in conjunction with ABG -Guidelines for the Movement and Treatment of Deceased or Injured Persons)

The MIG must ensure that no ABG employee, contractor or visitor to the mine site takes any photographs of the deceased using cameras, video cameras, mobile telephones or any other medium that can be used to store such images.

If the Tanzania Police Force cannot be contacted or located within a reasonable time the MIG will forward a request through the Manager - Investigations to have the appropriate police response.

If a post mortem examination to be conducted, the MIG will ensure that there is no interference to the body by any ABG employees.

The Site Security Manager will provide advice and assistance to management on the best practices for having immediate family members in any overseas country advised of any such deaths (either through the appropriate Consulate or law enforcement agencies).

For "Non Suspicious Deaths' the MIG will ensure that ALL property belonging to any deceased ABG employee, contractor or visitor to site, is fully itemized and recorded in the presence of a witness. All property is to be entered and recorded on the relevant secure base entry and lodged through the MIG. Continuity and accountability for all property must be maintained and an indemnity receipt will be obtained from the person who the property is returned to at the conclusion of the investigation.

5.7 Injuries/deaths to illegal miners or detainees


• In addition to all other requirements, an investigation (Category A - C) into any death or serious injury to an illegal miner by MIG personnel must comply with the following policy:

• MIG are conducting the investigation on behalf of the company and OGC and NOT the police.

• Any requests by the Tanzania Police Force for assistance OR any documents or other investigative material are to be IMMEDIATELY referred to Legal Counsel



Version Date: May 10,2010 Document Controller: Cassie Boggs

• All information is to be marked "Legal and Confidential and subject to legal privilege"

• The Senior MIG member on duty at the time of the incident will take control of the incident involving any fatalities or serious injuries that may result in a fatality for the purpose of conducting a thorough investigation.

• The MIG on duty will inform Security Control Centre of the time and date that they arrive on the scene and take control of the investigation.

• The MIG will liaise with HOD's from Surface Mine, Safety and any other relevant sections regarding any possible safety issues or for any other assistance that MIG requires.

• The MIG will immediately ensure that medical treatment is provided to any injured persons.

• The MIG will ensure that no un-necessary examinations are conducted on any deceased person and the body of the deceased person is immediately taken to the nearest Hospital Mortuary. This policy must be read in conjunction with 'ABG - Guidelines for the Movement and Treatment of Deceased or Injured Persons".

• The MIG will be responsible for taking control of any possible crime scenes and preserving physical evidence

• The MIG will be responsible for providing updates and situation reports to the Group Security Manager and must ensure that all deaths or serious injuries are reported to the Tanzania Police Force.

• The MIG will be responsible for overall investigation of the incident including the submission of the final investigation report.

Any death or serious injury investigation file MUST contain the following information;

• Photographs of the person and all injuries. Only MIG Investigators are authorized to take such photographs and will be responsible for the secure storage of those images. The images are NOT to be stored in electronic folders on the computer, but should be placed on a USB stick and locked in a safe controlled by MIG. Only one copy of the photographs is to be printed. All photographs after being transferred to a storage device must be immediately deleted from the MIG camera. All photographs (hard copies and images stored on a USB stick) must be delivered to Legal Counsel at the conclusion of the investigation. No images are to remain on site in the possession of any person.

• Photographs of the scene (if possible/practical) • Scale map of the scene - using on site Surveyors/Engineers and GIS

Mapping Section • Medical report • Geotechnical Engineers report if applicable • Hydrographic records • Secure Base report




5.8 Product theft investigations


In addition to all other requirements, an investigation into any internal product theft must also contain the following information;

• The Head of Department Processing OR his delegate MUST be advised when any product which appears to have been stolen from any of the processing plants is located.

• The Head of Department Processing OR his delegate MUST be given the opportunity to observe the exhibit in its original form.

• The Head of Department Processing OR his delegate may be then able to assist MIG in establishing from which particular area of the processing plants the product was stolen from. This information is vital as part of the investigation process and provides a level of expertise and direction that may assist in identifying any suspects.

• Any exhibits found to contain mercury are NOT to be stored in the MIG office (Refer to Standard Work Procedure - Exhibits).

• A security seal must be placed on all product exhibits at the time they are seized. The security seal number must be recorded in the exhibit register.

• The weight of the product must be recorded on the exhibit log and in the exhibit register.

• Product must be subject of an assay to establish the weight, concentration and value of any contained gold

• Continuity of the exhibit must be maintained and recorded in the exhibit register including the time, date and manner of disposal of the exhibit.

• All product exhibits must be photographed. • Prior to ore product being sent to assay lab the weight must be checked at

the investigation office for comparison and confirmation.

For any product theft investigations that may lead to criminal proceedings, advise is to be sought from the Legal Counsel before the exhibit is altered or tampered with in any way. The exhibit should not be assayed unless directed to do so by the court.

5.9 Weapons discharge investigations (To be read in conjunction with Barrick Security Procedure For the Use of Force - Part 4)

5.9.1 Specific requirements for lethal ammunition discharges;




In addition to all other requirements, an investigation (Category 1 or Category 2) into any discharge of lethal ammunition by Security personnel must also contain the following information;

• Copies of the training records of the person whom discharged the weapon • Copies of the relevant "Authority to Issue Firearm" form • Copies of the relevant records from within the armory • Original "Ammunition discharge" notification • Secure Base report

Every completed weapons discharge file must be delivered by hand to the Site Security Manager for review, and the Secure Base record annotated to reflect the file location.

The Site Security Manager will retain the only copy of this file. No other copies are to be made or held by any other person except with the express permission

.' of the Site Security Manager, Mine General Manager or OGC.

'. 6 Incident scene attendance and examination

The scene where any type of incident occurred should always be examined to establish whether any relevant evidence exists. The following principles should be applied in all circumstances;

6.1 Establish if the scene is a "Police Crime Scene" or "Non Police Crime Scene"

Establish if the scene relates to a death or serious injury that must be reported to the Tanzania Police Force and if so this scene must be secured and treated as a police crime scene. The only time that the scene can be entered or interfered with is to preserve evidence that may be lost or destroyed before the police arrive or if the police do not attend within a reasonable period of time.

6.2 Secure the scene

Ensure the area where any evidence does or may exist is secured by whatever means appropriate (tape, people, fencing etc) until a complete examination has been made, and the scene released for normal operations.

6.3 Safety assessment

BEFORE MIG INVESTIGATORS ENTER, ensure the scene is safe. Consult with area owners and Emergency Response personnel if appropriate. This is to be completed simultaneously with securing the scene.




6.4 Manage the scene

Once the scene is secured and safe to work in, plan out work to be conducted. Include paths for access, appropriate management strategies for individual items or areas, notification of stakeholders, and restoration protocols.

6.5 Identify the evidence

Before anything is touched or moved, damaged or destroyed, identify every piece of evidence, or potential evidence.

6.6 Record the scene

Make appropriate records for the circumstances, including the use of photography, digital imagery, maps, sketches, plans, or notes. Ensure the records include specific reference points and a complete record is made to enable production of a detailed and accurate plan. Record evidence in the position it was found before it is touched or removed.

6.7 Gather the evidence

Collect each individual piece of evidence. Store and move evidence according to its requirements, do not cross contaminate evidence, or store it in a manner that will cause deterioration or possible damage. Where documents are involved, always obtain the original and not a copy. Copies can be left in the relevant work area.

6.8 Return the scene to owner or normal operations

Once all of the previous steps have been completed, conduct a final inspection to ensure nothing has been missed or forgotten, and then return it to its previous condition, or release the area to the owner to commence reparation or clean up work as required. Ensure all stakeholders are notified.

6.9 Recording investigations on Secure Base

• All investigations must be entered into the SecureBase database as soon as is practicable

• All Secure Base fields MUST be populated with the relevant information. • All original documents must be scanned and stored as a PDF file within

the relevant SecureBase entry. • All investigations must be marked "Confidential- Yes" within the database

to prevent unauthorized access and secure the files within the server.




7 Case file management

All case files for Category A -C investigations must have a hard copy. Within the hard copy file, the following minimum presentation standards must be applied;

• Manila folder with only the Case File Number (from SecureBase) marked on the external cover. No other information is to be displayed on the external cover.

• Secure Base Incident Report - with the running sheet completed in the 'Required Actions (except in the case of deaths or serious injuries). The running sheet must contain an entry for every event that relates to the case file, including the time, date, and name of the investigator involved, and the complete details of the event related to the case file.

• Documents related to the case file should be stored within plastic protective sleeves, and be secured.

• Copies of digitally recorded records of interview are to be copied onto a compact disc and the compact disc is to be stored with the case file.

7.1 Documentation within case files

The following documents are the minimum required for any Category A-C investigations.

• Running sheet(s) completed on Secure Base - Required Actions (except in the case of deaths or serious injuries)

• A copy of the Secure Base Incident Report • Investigation report • Original signed statements (witness or ROI)

In addition the following items will be commonly held within case files;

• Original photographs (if applicable) • Documentary evidence • Case notes • Copies of emails and other correspondence

The following documents are the minimum required for any Category D-E investigations.

• Running sheet(s) completed on Secure Base - Required Actions • Original signed statements (witness or ROI) • A copy of the Secure Base Incident Report.




8 Allocation of investigations

The Operations Manager will review all tasks assigned to the MIG and determine what resources will be allocated to the task and its' particular category and priority. If any doubt exists as to whether the task requested is a matter requiring investigation by the Unit, the matter should be referred to the Manager -Investigations for clarification.

Every investigation will be assessed and assigned to an individual investigator by the Operations Manager. The person to whom the file is assigned becomes the primary person responsible for the carriage and completion of the investigation.

The Operations Manager will allocate and manage all investigation files through the Secure Base system in accordance with this Policy.

Unless otherwise required by the OCG, all Category A investigations MUST be undertaken by the Investigations Superintendent at a minimum.

9 Handover of investigations

Prior to any investigator going on field break or leave, all investigations files held by that person MUST be brought to the Investigations Coordinator for review.

If an investigation cannot be completed for any reason, by the person it is assigned to, then the following process MUST be followed;

A written record of the reason for non completion must be made within the running sheet recorded on the Secure Base - required actions and; If the file is to be reassigned to another person by the Regional Investigations Manager and this is to be recorded on the Secure Base- required actions log.

10 Interviews

All interviews with all types of persons must adopt and practice the following principles;

• Be conducted in a private and safe environment • Be conducted treating the person interviewed with dignity and respect • Be conducted in accordance with all relevant legislation, policy, and

procedures • Be conducted in a non threatening or aggressive manner • Be conducted giving full consideration to the age, gender, physical

capacity, mental state, educational background, language ability, marital status, religious belief and practice, and cultural practices or beliefs of the




person being interviewed. This means that where any of the previously mentioned considerations have, or may have, the potential to impact adversely on either the witness or the matter being investigated, the positive physical steps must be taken to minimize or eliminate the negative impact(s) on the person being interviewed (first priority) and the investigation (second priority)

10.1 Witness interviews

Where possible and practicable, the following principles should be applied to witness interviews;

Investigators must establish when commencing an investigation the work, leave, and field break commitments of each witness or potential witness, to determine the timing of interviews. Witnesses should, where possible, be interviewed as soon after the event as possible.

All statements are to be typed in English.

All statements MUST include information about the person making the statement to attest to the fact that they can OR cannot read and write English. (Example below)

I am a 30 year old married woman and I come from Nyangoto Village, Tarime District. I went to (Name) High School and completed grade 7. I can read a little bit of English and I can write some English. My first language is Kiswahili. I also speak Masai and English. I have been working at the mine site for the last 9 months.

If the person cannot read of write English and the statement was translated from another language into English - this information must be included in the statement. (Example below)

I am a 30 year old married man and I come from Nyangoto Village, Tarime District. I cannot read or write English. I did not go to school. My first spoken language is Kiswahili. I also speak Masai. When I made this statement I spoke in Kiswahili and I was told that my words would be translated into English. I was told that at the end of the statement, the statement would be read back to me and explained in Kiswahili.

If a person cannot read or write English then the statement MUST be read back to them and explained to them in a language that they understand (preferably by an independent person who was not involved in the taking of the statement). The person who read and explained the statement to the person MUST endorse




the statement in their own handwriting with the time and date that they read the statement back to that person. (Example below)

The statement was read back to (name of the person) and explained to them in Kiswahili by (name of the person who read and explained the statement). This person understood and agreed with everything contained in the statement. Signed. Time & date.

Where multiple witnesses exist, efforts should be made to keep each witness separated from others until the interview process is complete. This is to prevent collusion between witnesses and to obtain the most accurate, reliable, and complete account of events possible.

Under no circumstances are details from one witness's statement to be copied and pasted into another witness's statement.

All witness statements must be recorded in writing as per the attached template, and stored within the secure MIG drive within the network at address; [Drive name]\lnvestigations\Case Files\[Relevant case file number].

1 0.2 Category A Witness statements:

All statements taken for a Category A investigation and any other investigation commissioned by the OCG, Country Legal Counsel must be endorsed at the top of the statement as follows;

"IMPORTANT NOTICE ABOUT CONFIDENTIALITY AND LEGAL PRIVILEGE: This entire document is subject to confidentiality and legal privilege. The document is produced for the dominant purpose of seeking legal advice or for the use in litigation."

Upon completion of the statement one hard copy is to be printed and signed by the witness and interviewing investigator. UNDER NO CIRCUMSTANCES is a witness or any other person except Legal Counsel to be given a copy of any Category A or commissioned investigation statements.

1 0.3 Category B - E Witness statements;

Except otherwise provided above, upon completion of the statement, a minimum of two hard copies are to be printed, then signed and dated by the witness and the interviewing member. The witness can ONLY be given a copy of the statement if providing such statement does not compromise the investigation. In cases where it is not appropriate to supply witnesses with statements they will be advised that they will be supplied with a copy of the statement when the investigation has been finalized. Statements are to be scanned, converted to a




PDF file and saved within the relevant SecureBase entry. The second original hard copy is to be stored within the Case File.

10.4Suspect interviews

Every suspect should be searched as soon as they enter the Investigations Unit, to establish whether they are in possession of any weapons, dangerous items, or items that may afford evidence of an Offence.

Where possible and practicable, the following principles should be applied to suspect interviews;

Where multiple suspects exist, efforts should be made to keep each suspect separated from each other until the interview process is complete. This is to prevent collusion between suspects and to obtain the most accurate, reliable, and complete account of events possible.

When evidence exists to show that there are reasonable grounds for believing that a suspect has committed an Offence and an investigator intends to commence criminal or internal disciplinary proceedings against that person the suspect MUST ON EVERY OCCASION BEFORE QUESTIONING COMMENCES be advised of their rights under the laws of Tanzania. Investigators have a duty to ask questions and try to establish facts surrounding incidents that occur on the mine site.

Where a suspect wishes to exercise any of their Rights, then every possible effort must be made to facilitate the exercise of those Rights. Failure to do so may result in disciplinary action, and also may make any admissions by the suspect inadmissible as evidence.

All suspect statements must be recorded in writing as per the attached template, and stored within the secure MIG drive within the network at address; [Drive name]\lnvestigations\Case Files\[Relevant case file number].

Upon completion of the Record of Interview, a minimum of two hard copies are to be printed, then signed and dated by the witness and the interviewing member. The suspect is to be given a copy if this will not compromise the investigation, and the second original is to be scanned, converted to a PDF file and saved within the relevant SecureBase entry. The second original hard copy is to be stored within the Case File.

Upon completion of the Electronic Record of Interview two hard copies are to be recorded onto a compact disc. One compact disc is to be given to the suspect if this does not compromise the investigation. The other copy is to be stored within the case file.



Version Date: May 10,2010 Document Controller: Cassie Boggs

10.5 Records of Interview

Listed are the mandatory requirements that must be contained within every Record of Interview;

10.5.1 Introduction

• Heading indicating a record of interview between and investigator and the suspect, including the location and date of the interview

• List of persons present and their roles during the interview • Time of commencement • Statement to suspect advising the nature of the investigation and the

allegations against him • Formal criminal caution • Formal advice of the existence of Constitutional rights • Invitation to exercise those rights • Inquiries as to the suspects language abilities • Explanation of the process of the record of interview • Request for name and other personal details • Invitation to participate in formal record of interview • Confirmation of any prior conversation

10.5.2 Body

• Invitation to recount events related to investigation and explanation, denial or admission

• Investigation specific questions, including confirmatory questions • Question to obtain corroborative evidence or probe answers more deeply • Questions to establish the who, what, where, when, how, and why of

every allegation or Offence • Questions surrounding each element of every Offence (if applicable) • Invitation to make closing statements • Invitation to read interview to date • Note stating time interview suspended for reading by suspect

10.5.3 End

• Question whether suspect has read (or had read to him) the record of interview

• Confirmation or otherwise of voracity of questions and answers • Invitation to change, add or remove any part of the record of interview for

any reason




• Questions to establish whether record made in the exercise of free will or otherwise

• Invitation to read last questions and sign document • Note of time and date completed • Signatures of interviewer, corroborator (if present) and suspect if he

chooses to do so

10.5.4 Manner of conducting interview

• Interviews should be conducted in a private and non threatening environment

• The interviewee should clearly understand he has the right to participate or stop the interview at any time he chooses, and can also exercise any of his Constitutional rights at any time

• Consideration should be given to the welfare of the interviewee, including (but not limited to) refreshment, toilet, and cigarette or other comfort breaks

• Details of any interruption(s) or break(s) should be entered into record of interview contemporaneously including the stop and recommencement times

10.6 Report writing

Investigators are required to prepare and disseminate written reports regarding a number of matters. In general, unless otherwise directed by this Policy or a direCtion issued under it, the reports should comply with the following general outline;

• All reports are to be addressed to the Manager - Investigations. • All reports must be submitted through the Manager - Investigations for

review. • Memorandum style including ABG logo • Arial 12 Font • Heading (Mine Investigations Group Security Department) • Address block- Manager - Investigations and whom copies are being sent,

name of author and section, date, and subject reference • Introduction that describes the circumstance(s) or incident(s) leading to

the need for the report • Identification of persons, property, and locations relevant to matter • Description of process(es) undertaken such as audits, interviews, and

evidence gathering techniques • Sequence of events (if relevant) • Established facts (including a description of evidence supporting the facts) • Identified breaches of policy, procedure, or legislation




• Person(s) identified as being responsible for breach(es} • Current disposition of all matters

Reports should not contain opinion or conjecture

11 Periodic reporting

The MIG shall furnish a report weekly as required (currently Friday to Thursday) including a summary of all investigations undertaken, the number and nature of all exception reports, and any other significant matters being undertaken or managed by the Unit. The report shall be completed no later than 12.00pm on the reporting day. The report is to be forwarded to the Manager - Investigations or designate via email.

12 Prioritization principles for tasking(s)

12.1 General approach

Common sense and flexibility must be applied in all cases. The MIG will conduct investigations on a priority basis according to impact and severity.

12.1.1 Urgent cases - Category A & B Investigations.

Priority A investigations will take the priority of resource allocation, followed by Priority B - E.

Where a lack of resources exists to commence a priority A or B investigation within 72 hours the matter should be escalated to the Manager - Investigations

12.1.2 Non urgent cases - Category C- E Investigations.

Non urgent cases will be completed as resources allow, however, ALL investigations are important and MUST be completed to at least the minimum required standard(s) without unreasonable delays.

12.2Competing interests and multiple cases

Multiple urgent and on going inquiries often exist together and a particular investigation may take precedence over another urgent case. Where this occurs, then a written record should be made within the running sheet of that less urgent file stating the time, date and reason for the delay. Stakeholders MUST be advised of a delay where the delay will or may result in the failure of the MIG to meet an agreed deadline.




12.3 Delays

On every occasion a delay will or may occur past an agreed timeframe or deadline, then the Manager - Investigations must also be advised as soon as practicable.

13 Confidential Informant Management

13.1 ABG Confidential Informant Management Policy

The utilization of confidential informants shall be conducted in accordance with the ABG Confidential Informant Management Policy.

14Surveillance Exception Reports & Relationship to Surveillance Units

Site based Surveillance Units are managed by the Site Security Manager. Exception reports will be reviewed by both the Site Security Manager (for site based departmental issues) and the Manager - Investigations and provided to the MIG as appropriate.

The MIG have the authority to enter a Surveillance Unit and review records, and to task the Surveillance Unit in order to conduct specific tasks for the purposes of an investigation.

Except in the case of emergency, prior notification of the reason why a MIG member requires entry to the unit shall be made to the Operations Manager. In the event of an emergency, notification MUST be made at the first available opportunity following such access. Failure to comply with this requirement may lead to disciplinary action.

14.1 Product from Surveillance Unit

Product from the Surveillance Unit is highly confidential and sensitive, and can only be used for legitimate investigative purposes.

Surveillance product should NOT be shown to suspects. Surveillance footage can be shown to a Head of Department or Senior Staff member involved in the disciplinary process such as prior to officially suspending an employee or during the disciplinary hearing.

If a genuine need to view the surveillance footage exists, consideration must be given prior to the current and future implications the disclosure may have, and




appropriate recording of the reason(s) for disclosure should be recorded within the case file.

15 Exhibit Handling

The MIG are responsible for the proper management of all property seized or acquired during the course of an investigation, or during the course of security functions carried out by security personnel.

All members of the MIG must comply with the Standard Operating Procedure titled "Exhibit Handling". Failure to comply will result in disciplinary action.

Exhibits are not to be left unsecured within the office area of the MIG. They must be stored as soon as practicable within the Exhibits Room at the MIG office. Exhibits received from other areas must be checked for accurate labeling prior to the person delivering the exhibit leaving the office, so that any error(s) can be rectified immediately.

Only members of the MIG, Corporate Security and Site Security Manager are permitted within the Exhibits Room.

Continuity of exhibits must be maintained and recorded on the exhibit log and in the exhibit register book. All exhibits MUST be entered on Secure Base.

160versight functions

The MIG is required to provide timely, relevant, and appropriate information to senior management of ABG so that ABG is in possession of sufficient facts and information to make decisions and implement strategies regarding operational effectiveness and efficiency where they deem it to be appropriate.

All information contained within reports must be supported by facts and evidence, and not contain opinion, speculation, assumption, hearsay, or other irrelevant information.

16.1 Arrests and detention

From time to time and as requested by the Group Security Manager, the MIG may be required to review the circumstances surrounding the arrest and detention of people by members of the Security Department.

Such reviews should involves interviews with prisoners or detainees to establish if the arrest process and detention complies with United Nations Human Rights guidelines, legislation, and ABG policy or procedures. All members of the




Security Department involved in the arrest or detention of the person should also be interviewed. All related documents and records should be reviewed to determine compliance or otherwise with applicable standards, and where appropriate seized or copied.

Reports regarding these matters should be marked confidential and delivered to the Manager - Investigations for review.

Unless there is evidence to support criminal conduct, or a serious breach of the Disciplinary Code or Safety, the report should be focused on "What went wrong" rather than 'Who did wrong"

16.2lnjuries caused by or during Security operations

Where any person (other than an Security member) is injured during activities managed or conducted by the Security Department, then the MIG should attend and make an assessment of the situation. The scene where the incident occurred is to be secured and no person should be permitted to enter the area until the initial assessment has been completed.

The injured person if seriously injured should be provided with immediate first aid treatment and then taken to the Mine Medical Centre (MMC) for stabilization before being transferred to the Hospital. The senior MMC member advised to conduct a thorough examination of the person in line with accepted medical protocols. The examining MMC member should also be advised to provide a written report as to the nature of the injury(s), their relative significance, and the likely or possible causes of the injury.

Photographs are to be taken of the injured person and each of the injuries by MIG members only.

When released from the MMC, or, in the opinion of the senior MMC member the injured person is able to be interviewed, a witness statement should be taken from the person or a statement should be recorded on a digital recorder. If there are any allegations of mistreatment or assault, a Category B investigation should be commenced immediately.

The Manager - Investigations is to be advised at the earliest opportunity of the circumstances or allegations.

Reports regarding these matters should be marked confidential and delivered to the Regional Investigations Manager for review.

16.3 Weapons use




On every occasion a member of the Security Department uses a weapon to discharge 'hard ammunition' whilst at work, either on or off site (except for approved training activities), an investigation (Category A) shall be conducted to establish whether the use of the weapon complied with legislation, ABG Policy and Procedures, and United Nations Human Rights guidelines.

Reference must also be made to the current ABG Security Procedure for the Use of Force

All incidents involving the discharge of non lethal rounds where no person is reported to be injured involving ERIW, gas rounds, gas canister and OC spray shall be referred to the Site Security Manager for review. Ammunition discharge notification form submitted by the person(s) discharging the non lethal round and this will be reviewed by the Site Security Manager.

After reviewing each Ammunition Discharge Notification Form the Site Security Manager MUST refer any ammunition discharges to the Manager - Investigations where the circumstances appear to not comply with ABGk Policy and Use of Force Guidelines OR may require further investigation for any other reason including random audits.

11.3.2. All non lethal ammunition discharges where no person is injured will be treated as Category C investigations. The Site Security Manager will review the documents to ensure that the discharges comply with Weapons Policy and Procedures. The Site Security Manager MUST review all non lethal ammunition discharge forms and sign the appropriate section of the form outlining that the file is complete or needs further investigation or the member involved needs further training. If there are no breaches of Policy and Procedure detected then no further investigation will normally be required. Any breaches of Policy and Procedure will automatically escalate this investigation into a Category B investigation.

16.4 Policy & Procedures

From time to time, the MIG may be required by the Group Security Manager to review policy and procedures within the workplace.

These reviews should always involve discussion and review with a competent person who is familiar with the workplace and policy or procedures.

The review process should include the following;

• Analysis of the intention of the policy or procedure • Whether persons affected by it are aware of its existence • The form of publication and its suitability for the intended audience




• Compliance within the workplace • Effect of policy or procedure within the workplace • Consequences of the policy or procedure within the workplace • Suitability for task of the policy or procedure • Security implications of the policy or procedure • Formulation of recommendations or changes if required • Consultation with all stakeholders • Written report to the Group Security Manager

The above process should also be undertaken when making an assessment where policy or procedures do not exist within a workplace, but a review has occurred due to an incident.

17Training within Security Department

The MIG are a specialist unit within the Security Department, and possess expert knowledge in relation to statement taking, interviews and preparation of court files.

It is the intention of the MIG to share knowledge and to provide high quality, oneon-one training to other members of the business unit who are required on a regular basis to obtain witness statements, conduct interviews and compile case files or investigation files for non security issues (Safety).

18 Preventative strategies

The MIG are focused on prevention as a core part of its business. The following actions should be conducted to encourage buy in for security strategies, and to deter employees from committing Offences;

• Conduct Compliance Audits at various workplaces • Conducting reviews of existing policy and procedures to establish

currency and effectiveness • Analysis of data to target susceptible workplaces or workgroups and

deliver relevant security toolbox meetings • Information sessions for new employees during induction on security

measures and policies • Conducting site inspections to introduce, improve, or review physical

security measures • Conduct random search operations within workplaces identified as high

risk • Review and analyze detected Offences or breaches of security and

develop, implement, and monitor new security strategies within high risk workplaces




19Targeted investigations

Where analysis of trends, reports, intelligence and/or information suggests a particular employee or contractor, or group of employees or contractors, are, or may be, involved in repeated or organized criminal behaviour, then an operation should be commenced with the goal of achieving the following;

• Identifying all persons involved and their associates • Identifying patterns of behaviour • Establish method of committing Offence(s) • Identify method of concealing Offence(s) • Identify how existing security procedures and practices are being

overcome or breached • Establish the most appropriate time and method of bringing the matter to

completion

20 Confidentiality

Members of the MIG must keep details of all matters under investigation confidential, and only discuss such matters with the parties directly involved or effected.

Information of any description can only be released from the MIG with the express approval of the Manager - Investigations.

21 Police and Courts

21.1 General

The MIG are primarily involved in conducting internal investigations into Offences and breaches of Policy and Procedures that are committed on the mine site or by ABG employees. MIG Investigators are not the police and it is not our role to conduct investigations on behalf of the police. The Tanzania Police Force is the principal law enforcement agency in the country and responsible for conducting their own independent investigations. MIG MUST not release any material to the police without prior written approval from Legal Counsel and the Group Security Manager.

Members of the MIG should maintain distance from, and not interfere in any way with conduct of external investigations by National Security Organs.




Any improper or illegal approach for assistance of any kind made to a member of the MIG by any public official must be reported immediately to the Manager -Investigations who shall refer the approach to the OGC.

21.2 Process serving and execution

Where a request is made by Police or other officials to enter site and serve or execute a legal process, then this matter should be facilitated through the MIG. Inquiries should be made to establish the nature of the request, its implications for operations within the mine, the urgency of the request, and the security implications, in consultation with the Site Security Manager.

The employee concerned should be contacted (unless there are genuine concerns over security) and advised of the nature of the process intending to be served on them and a mutually agreed outcome determined. If the employee refuses to cooperate, then the MIG should provide whatever assistance it is lawfully able to give to assist in the execution of the process or warrant. Where possible, the process should be served outside the workplace, and in such a manner as to minimize disruption to production.

22Court files

22.1 Crime reports and arrests

Members of the MIG must submit all requisite information to the Police Station Commander and Officer in Charge of the Criminal Investigation Division at the relevant locations. This should only be done after consultation with the Site Security Manager and Manager - Investigations.

Where any member of the MIG makes an arrest, then that person must be handed over to police as soon as practical to allow proper process to be followed.

23 Records Management

The Information Records generated as a result of this Policy shall be retained as provided for in this Policy or in any approved Corporate Records Management Policy.

Records in relation to all Category A and B investigations shall be retained for a period of 7 years in the files of the Office of General Counselor delegate. The files in relation to these investigations shall be sent to the OGC or delegate at the conclusion of the investigation. The OCG or delegate shall review before destruction.




Records in relation to all Category C- 0 investigations shall be retained for a period of 7 years after the closing of the investigation or the completion of any legal or disciplinary action arising from the investigation. These records shall be stored as per the procedures outlined in this Policy as amended from time to time, and in the event that storage capacity is unavailable, the Manager -Investigations shall contact the OGC or delegate to make arrangements for alternative storage.

Records shall be secured either in a secure system ie SecureBase or under physical lock.

All other records shall be kept for a minimum of 7 years from the creation of the record.

The movement of any Information Records shall be recorded in Securebase or other Barrick records management system.

24 References

Tanzanian Legislation . ABG Policy & Procedures

ABG Code of Conduct ABG Gold Security Standards UN Documents - Voluntary Principles on Human Rights and Guidelines for Law enforcement and security personnel




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