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Oyu
Tolgoi

Oyu Tolgoi LLC

People and Organization

HR-H4: Expatriate
Code of Conduct
 Contents

Introduction .......................................................................................................................... 2

1..................................................................................................................Policy Number
2

2...............................................................................................................................Purpose
2

3........................................................................................................................Application
2

4..................................................................................................................Commencement
2

5.............................................................................................Authority and Management

2

Code of Conduct...............................................................................................................................3

6.....................................................................................Importance of Personal Conduct

3

7.........................................................................................Appropriate Personal Conduct

3

8..................................................................................................................Consequences
4

9.........................................................................................................................Dependants
5

10........................................................................................................................Definitions
6

Document Information........................................................................................................................6

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a

Introduction
1. P o l i c y N u m b e r This document is known as HR H4 Expatriate Code of
-

Conduct.

2. Purpose
This HR-H4 Expatriate Code of Conduct outlines the required standards of behaviour for
expatriates whilst living and working in Mongolia.

3. Application

This Code of Conduct applies to all expatriates in Mongolia who are employed or associated
with Oyu Tolgoi LLC (OT) including:
Employees of OT or Rio Tinto
Employees of contractors & subcontractors
 Consultants, guests or Oyu Tolgoi LLC visitors.

This Code of Conduct is part of the contract between Oyu Tolgoi LLC or Rio Tinto and any of its
workers, contractors, suppliers or visitors. Management and supervisors are required to explain
its contents to all staff and ensure personnel have fully understood these requirements.

This Code of Conduct applies in addition to The Way We Work and any other policies of Rio
Tinto and or Oyu Tolgoi LLC.

4. C o m m e n c e m e n t This Code of Conduct applies from 1 June 2017.

5. Authority and Management

This amended Code of Conduct was approved by the General Manager People &
Organisation on 31 May 2017.

It will be reviewed annually or as necessary.

The People and Organization department are the custodians of this Code of Conduct. Any
requests for changes to this Code of Conduct must be addressed to the department and will be
subjected to the appropriate review and approval processes.

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Code of Conduct

6. Importance of Personal Conduct

Oyu Tolgoi's goal is to build enduring relationships with our colleagues, business partners,
government authorities and other members of the community. These relationships should
demonstrate mutual respect, active partnership and long term commitment to Mongolia.

As a result, personal conduct and behaviour are fundamentally important in ensuring long term
success in Mongolia.

Expatriates at Oyu Tolgoi LLC are expected to demonstrate personal conduct and behaviours
that reflect Oyu Tolgoi's and Rio Tinto's business and leadership values.

As Oyu Tolgoi LLC is supporting each expatriates' visa to work and/or live in Mongolia, it is an
essential requirement of every expatriate engagement that you display appropriate behaviours
when working and living in Mongolia, and do not engage in any conduct that could breach
immigration, visa requirements and Mongolian laws generally. This requirement applies to your
conduct regardless of whether it occurs within or outside of work hours.

Any behaviour or action that brings you, the Company or the Company's reputation into
disrepute will not be tolerated.

7. Appropriate Personal Conduct

Expatriates associated with or employed by Oyu Tolgoi LLC are expected to comply with the
law and this Code of Conduct at all times.

In all circumstances, whether inside or outside of work, expatriates are expected to act with
integrity, model appropriate personal conduct, as well as actively coach their colleagues to do
the same. It is especially important to understand and respect the concept of Mongolian
natural wealth - which can include, but is not limited to, people, culture, nature (flora, fauna,
minerals), history etc.

Examples of Appropriate Conduct

 Demonstrating sensitivity and due regard for the cultural norms of Mongolia and
its people;
 Observing and complying with all Mongolian laws;
 Complying with The Way We Work, OT values and OT policy/procedures that
apply;
 Abstaining from drug and/or alcohol consumption in the workplace, or in any
manner outside the workplace that affects your ability to do your job, or harms others;
 Behaving in a safe, respectful and professional manner and not being involved in
any situations which could compromise your personal safety or security, or the safety
and security of others around you;
 Reporting all safety, security, violent incidents, or threats immediately, and/or
contact authorities in case of imminent danger;
 Safely stopping a non-compliant situation and providing coaching to improve
it.

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Examples of Inappropriate Conduct
Not observing and/or complying with Mongolian law;
Disrespectful behavior towards the Mongolian customs or people, including destruction or
misappropriation of Mongolian natural wealth;
Failing to report any relationship which could be considered a potential conflict of
interest. A potential conflict of interest can arise where the relationship is with direct or
indirect reports, co-workers, or employees of contractors, where the expatriate is
deemed to be in a real or perceived position of power;
Frequenting adult entertainment venues, engaging in prostitution activities or sexual
exploitation;
Engaging in any act that supports or is likely to support human trafficking or the harm of
children;
Illicit drug use;
Inappropriate, illegal or irresponsible behavior while on company related business or while
attending official functions;
Bribery of government officials or any other type of corruption;
Failing to comply in any way with Rio Tinto The Way We Work;
 Any behaviour that would be deemed unlawful in Mongolia.

This Expatriate Code of Conduct cannot cite the complete range of appropriate or inappropriate
behaviour across a variety of situations or dilemmas. However, whenever in doubt, work
through these questions for an integrity check:

Is what I am doing ethical and in line with the Expatriate Code of Conduct?
Is what I am doing legal, and, or, am I authorised to do it?
 Am I being culturally sensitive to local Mongolian people and cultural
customs?
Have I thoroughly considered the potential risks, including the risks to Oyu Tolgoi's
reputation?
Is it the right thing to do, and am I leading by example?
 If this becomes public knowledge, will I still feel I have done the right thing?

If you would like advice on any matter relating to the Expatriate Code of Conduct, or wish to
report a concern, speak to your leader in the first instance, or a Human Resources
representative.

8. Consequences

Any suspected breach of this Code of Conduct will be thoroughly investigated. This process
may result in action being taken against an individual (by Oyu Tolgoi LLC, or a contractor, or
both) which may include:

 Formal disciplinary proceedings

 Withdrawal of visa support
 Removal from site
 Termination of International Assignment
 Termination of employment

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