The Kinross Code of Business Conduct and Ethics (Code) establishes policies for Kinross directors, employees and contractors, and applies to all Kinross operations and to Kinross-operated joint ventures.
The Code is available in all of the applicable official languages and addresses workplace policies, environment, health and safety issues, third-party relationships, legal compliance, confidentiality issues and the use of Kinross assets. We carry out compliance training and education programs with all sites and regions to ensure employees understand and respect Company expectations for ethical behaviour and compliance, and risks of non-compliance with the Code. In addition, all employees in management roles are required to acknowledge by signature on an annual basis that they have read and understood, have not violated, and are not aware of any violations of the Code.
The Code and the associated training establish strict controls to prohibit corruption, including participation in any bribes, kickbacks, or improper inducements or payments to any public official. In 2013, we strengthened our policy regarding respect for human rights by expanding the Code’s prohibition of any kind of discrimination or harassment in the workplace, at company-related events, or through electronic media.
Our Whistleblower Policy provides employees and non-employees with mechanisms to confidentially report actual or suspected improper activities regarding of the Company’s accounting, internal controls or auditing matters, and any other violations of the Code including, but not limited to, violations of applicable laws and Kinross policies.
In February 2013, the Board of Directors approved various updates to the Code, Whistleblower Policy and the Disclosure, Confidentiality and Insider Trading Policy. In addition, the Company has established a position of Vice-President, Compliance to provide dedicated leadership and oversight of the Company’s global compliance program.
Although not an area of strategic focus, donations to political parties and politicians are made from time to time in accordance with the Code, Kinross' Corporate Donations and Sponsorship Policy and approved by the Executive Vice-President, Corporate Affairs. Kinross made $325,000 in political donations in 2012 (an election year in Brazil and the U.S.), and $6,400 in 2013.