EX-14.1 4 fcxpbcglr.htm EXHIBIT 14.1
Principles of Business Conduct STRENGTH IN VALUES 1

STRENGTH IN VALUES

OUR VALUES: WHO WE ARE AND HOW WE WORK – EVERY ONE, EVERYWHERE, EVERY DAY. Safety Integrity Safety first—for ourselves, our coworkers and our We are honest, transparent and responsible. communities. n We are truthful and sincere. n We promote safety, and health and wellness at our n We communicate openly and accurately, inside and operations and in the communities where we live and outside the Company. work. n We do what we say we will do. n No job is so important and no schedule so urgent that time cannot be taken to plan and perform work in a n We take responsibility for our words, actions and safe manner. decisions. n Safe production requires that: Excellence - We report to work fit for duty, take responsibility for We pursue excellence in our work. our own safety and look out for the safety of others. n We take pride in our work and always do our best. - We follow safety standards and controls, and identify and eliminate potential hazards. n We promote change, explore new options and challenge accepted practices. - We have the authority and responsibility to stop work if it is not being performed safely. n We collaborate to create and implement innovative ideas and to develop solutions to issues and - We promptly report safety incidents. concerns. Respect n We work with purpose to deliver high-quality results. We treat each other and our stakeholders with respect. Commitment n We are courteous to each other and those with whom We are committed to contributing to the long-term we engage. sustainability of the environment and communities where n We value the diversity, ideas, perspectives and we work. experiences of our employees and our stakeholders. n We are accountable for our environmental and social n We make decisions without favoritism or negative performance. bias. n We strive to mitigate potential adverse environmental n We embrace a culture that supports the free flow of and social impacts throughout each project’s life information and sharing of ideas. cycle. n We engage in opportunities to maximize the benefits our operations deliver. n We partner with our stakeholders to build local capacity and self-sufficiency beyond the presence of our operations.

TABLE OF CONTENTS LEADERSHIP MESSAGE................5 STRENGTH IN VALUES: OUR MARKET...............................28 OUR RESPONSIBILITIES................6 Promoting Fair Competition...........28 Leading by Example.........................6 Responding to Inquiries from Investors, Analysts and Suppliers...........................................7 the Media........................................30 Making Ethical Decisions..................7 Avoiding Insider Trading.................32 Adhering to International STRENGTH IN VALUES: Trade Regulations...........................33 OUR PEOPLE..................................8 Promoting a Safe and STRENGTH IN VALUES: Healthy Workplace...........................8 OUR STAKEHOLDERS.................34 Valuing Diversity and Inclusion.......10 Contributing to Our Communities................................. 34 Promoting a Respectful Workplace.......................................12 Respecting Human Rights.............36 Ensuring a Drug- and Protecting the Environment............37 Alcohol-Free Workplace.................13 Fighting Bribery and Protecting Employee Privacy Corruption........................................38 and Information..............................15 Participating in Political Activities........................................40 STRENGTH IN VALUES: OUR COMPANY............................16 HOW WE UPHOLD THE PBC......................................41 Avoiding Conflicts of Interest.........16 Investigations.................................41 Outside Employment and Activities.....................................18 Cooperating with an Investigation Process.....................41 Personal/Significant Financial Interests......................18 Disciplinary Actions........................41 Relationships with Family Waivers...........................................41 and Friends................................19 Gifts, Meals, Travel and THE IMPORTANCE OF Entertainment.............................20 SPEAKING UP..............................42 Detecting Fraud..............................22 Reporting Possible Violations and Getting Help............42 Creating and Maintaining Accurate Books and Records........22 No Tolerance for Retaliation...........42 Managing Our Records FCX Compliance Line....................42 Appropriately...................................23 Resources.....................................43 Protecting Our Confidential Information and Intellectual Property..........................................24 Protecting Company Assets...........26 4

LEADERSHIP MESSAGE Dear Employee, Safety, Respect, Integrity, Excellence and Commitment. These are not just words at Freeport-McMoRan. They are the core values on which this Company has built its reputation. These values are what make us strong. Titled Strength in Values, our Principles of Business Conduct represents Freeport-McMoRan’s culture and commitment to doing what is right. Designed to help guide all of us—from top-level management to entry-level employees— the PBC is how we do business. It is essential you read, understand and follow our PBC. It covers a variety of business situations—from promoting a safe workplace to complying with laws and avoiding conflicts of interest to developing positive relationships with our local communities. Using the PBC will help you apply these core values to your daily business decisions and actions. If you are not sure about something, ask. Never hesitate to seek help if you are uncertain about a legal, compliance or ethical issue. By living our values each day, we ensure the Company maintains its reputation and continues to prosper. You—our employees—are the core of this Company and what makes it successful. I am proud of the great efforts you put in daily and your dedication to our success. Understanding and embracing the PBC and our values demonstrates your commitment to the Company’s future, and the future of our families and communities. On behalf of the Board of Directors and our leaders around the world, thank you for all you do. Sincerely, Richard C. Adkerson Vice Chairman, President and Chief Executive Officer Freeport-McMoRan | Principles of Business Conduct 5

OUR RESPONSIBILITIES As employees, we are responsible—individually and collectively—for how FCX conducts business. Following the PBC gives us the strength to do what’s right. We do our part when we: n Act with honesty and integrity n Follow the law and FCX policies and procedures n Treat each other with respect n Use common sense and sound judgment At FCX, we lead n Seek guidance when unsure about the right thing to do by example and n Speak up when we see a problem uphold the PBC n Cooperate with investigations and our values. n Complete all assigned training FCX will train all employees in the PBC. All new employees will receive training as part of the new-hire process, and additional training in the PBC will be provided periodically. Select employees, including certain managers, supervisors and other Company leaders, are required to certify their understanding of, and compliance with, the PBC and values on an annual basis. Leading by Example Each of us has the opportunity to be a leader—at work, at home and in our community. At FCX, we lead by example and uphold the PBC and our values. We also help to ensure that those who report to us and those we work with understand our PBC, values and applicable policies, procedures and laws. Leaders set the right tone by: n Demonstrating the highest ethical standards and quality in our work and expecting the same from every team member n Being proactive and taking steps to prevent problems before they happen n Encouraging employees to speak up when something is wrong n Ensuring all employees complete any necessary or assigned training n Being visibly engaged and proactive in supporting ethics and compliance matters 6 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

Suppliers FCX believes in doing business only with suppliers of goods or services, including contractors, consultants, vendors, their subcontractors and any other contracted third parties (collectively Suppliers) who share our values and demonstrate a high level of ethical and legal conduct. We seek to establish mutually beneficial, long-term relationships with business partners who demonstrate their commitment to our Supplier Code of Conduct (Supplier Code) and ensure their employees working at Company operations or on FCX’s behalf understand and follow the Supplier Code. We expect our Suppliers to abide by the laws of the countries in which they operate and behave according to the Supplier Code. All suspected violations of the Supplier Code should be reported immediately through the resources outlined in the PBC. The Supplier Code is in addition to, and does not reduce or supersede, any contractual obligations. WHAT WE DO: WHAT WE DON’T DO: We require Suppliers to: n Permit Suppliers to use child labor or forced labor n Provide their employees with a healthy and safe workplace n Allow any kind of bribe, kickback or other form of personal payoff n Operate in compliance with all tied to our business arrangements local laws and regulations n Uphold and follow the Supplier Code For additional Supplier information, please see the Supplier Code. Making Ethical Decisions Making ethical decisions requires a commitment to do the right thing regardless of the cost, to act consistently and apply the PBC and our values each day, and to consider any potential consequences. The questions below will help you think through a difficult decision so that you can make smart and ethical business decisions. If you answer “no” or “I don’t know” to any of the questions, talk to your supervisor. Is it legal? Is it consistent Can I rationally Would I want with our PBC, and honestly to see this values, policies defend my published in the or procedures? decision? news? Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 7

SAFETY... STRENGTH IN VALUES: We promote safety, and health and wellness at OUR PEOPLE our operations and in the communities where we Our employees are our greatest strength. Ensuring a live and work. safe and healthy workplace where everyone is treated fairly and with respect is a high priority at FCX. We operate in regions of varying ethnic, religious and cultural backgrounds and are often the largest employer in local communities. The diversity and various perspectives of our workforce make us stronger. Promoting a Safe and Healthy Workplace Our highest priority is the health and safety of our employees and their families. Our objective is for zero workplace fatalities, injuries and occupational illnesses. We are committed to providing a safe and healthy workplace and ensuring we all have the knowledge, skills and attitudes needed for Safe Production. Safety is an integral part of every job we do. No job will be considered so important and no schedule so urgent that time cannot be taken to perform work safely. We should feel safe at our place of work at all times. If you ever feel you are in danger, talk to your supervisor immediately or contact your local Health and Safety representative. STRENGTH IN VALUES 8

FCX provides the training, tools and resources needed for employees to Values in Action identify risks, eliminate hazards and work safely. If at any time you do not feel that you or a coworker can perform a job in a safe manner, stop work immediately and talk to your supervisor. Always report any unsafe conditions Q. and job-related injuries or illnesses immediately. We have two furnaces down for regular maintenance when a third Each of us has a responsibility to eliminate risky behaviors and recognize, furnace needs an unscheduled report and correct health and safety hazards. If a hazard cannot be eliminated, repair. Not wanting to waste time, employees must work together with supervisors and safety staff to ensure that my coworkers create a platform it is effectively controlled. We share information about potential fatal events, out of large equipment and near misses, best practices and other safety-related information throughout the shipping crates rather than waiting Company so we can learn from each other and improve safety practices. for the appropriate scaffolding. The For additional information, please see our Corporate Safety and Health Policy platform is unstable and does not on FM Web. meet safety requirements. I know we’re under pressure to get the WHAT WE DO: WHAT WE DON’T DO: repair done, but it’s not safe. What should I do? n Report to work fit for duty n Begin a job without proper planning n Take responsibility for our own A. safety and look out for the safety n Take unnecessary risks of others STOP the work immediately. n Ignore unsafe situations No job is so important and no n Follow safety standards and use schedule so urgent that time n Lessen the importance or severity critical controls to eliminate poten- cannot be taken to plan and of safety incidents or near-miss tial hazards and minimize risk perform work in a safe manner. events to avoid reporting Recognizing safety hazards and n Stop work immediately if it cannot taking immediate action is a be done safely responsibility we all share. Contact n Report all unsafe conditions, your supervisor and your safety safety incidents and near misses manager so the platform can be designed and installed properly to n Participate in required training ensure no one gets hurt. 9

Values in Action Valuing Diversity and Inclusion The many cultures, perspectives and life experiences of our people are a Q. source of strength at FCX. We are committed to a workplace where everyone I recently interviewed for a large feels like they belong, where they are treated with respect and their opinions equipment operator position within are valued, and that encourages people to speak up and share ideas. These the Company. When the hiring ideas help drive innovation and operational excellence. manager called to tell me I did not get the job, he said, “Shauna, you WHAT WE DO: WHAT WE DON’T DO: have a lot of driving experience, n Treat each other with respect n Allow personal opinions of a but I just don’t know if you can and are courteous to each person’s culture, appearance or handle fully loaded equipment of other and those with whom lifestyle to affect our ability to this size like the guys.” I have been we engage make smart business decisions driving large equipment for years and never had an accident. It n Seek out and value diverse n Show favoritism or bias based on shouldn’t matter if I am not a guy. points of view and the unique personal beliefs Should I say something? contributions of everyone with whom we work A. n Encourage and reward teamwork Yes. We treat people fairly and do n Make employment decisions not make decisions based on based on facts and business gender. We value a diverse work- needs rather than favoritism force and the individual skills and and bias experiences of our employees. Talk to your supervisor or Human Resources representative. 10 Freeport-McMoRan | Principles of Business Conduct

RESPECT... We value the diversity, ideas, perspectives and experiences of our employees and our stakeholders. 11

RESPECT... Promoting a Respectful Workplace The Company promotes a positive and productive work environment in which We are courteous to every employee is respected and valued. Harassing behavior works against each other and those these efforts and violates our value of respect. FCX does not tolerate any form with whom we engage. of harassment or discrimination. Harassment includes derogatory, degrading or demeaning words or gestures, such as making comments to a coworker based on race, color, sex, religion, national origin, sexual orientation, gender identity or expression, disability, Values in Action age, veteran’s status or any other characteristic protected by law. It also includes violent or threatening behavior. You must exercise caution when Q. making offhand comments or jokes and be sensitive to the fact they could unintentionally hurt or offend another person. My supervisor, Barry, received a new project with a tight deadline requir- WHAT WE DO: WHAT WE DON’T DO: ing our team to work overtime. When I volunteered to work extra n Think before we act or speak— n Make comments or gestures, or hours, he said, “Great, our oldest recognizing how actions and engage in violent or threatening team member just volunteered. I comments might be received or behaviors, that create an never thought of you as someone misunderstood by others intimidating, hostile or offensive who would be willing to work work environment n Act in a considerate, courteous overtime.” The team laughed, and and appropriate manner n Verbally abuse others or make others slowly began to volunteer. I sexual, ethnic or racist jokes was embarrassed and offended by n Report harassment or and comments his comment and spoke to Don, my discrimination without fear Human Resources representative. of retaliation n Use inappropriate or offensive Did I make the right decision? language n Display pornography or any A. kind of offensive pictures, objects Yes. You should speak up if some- or symbols one says or does something that n Pursue unwanted physical makes you feel uncomfortable. If contact or unwanted sexual you’re not comfortable discussing or personal advances the situation with Barry directly, you can discuss it with your Human n Offer job benefits in exchange for Resources representative. Each of sexual or other favors us should expect respect in the workplace. SEXUAL HARASSMENT TAKES MANY FORMS All forms of sexual harassment go against our values and are prohibited by FCX. These include, but are not limited to, unwelcome physical contact of a sexual nature, requesting sexual favors in exchange for job benefits, threatening penalties if sexual favors are not granted, and any conduct of a sexual nature that interferes with an individual’s work performance or creates an offensive work environment. 12 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

Ensuring a Drug- and Alcohol-Free Workplace SAFETY... To do our jobs safely and efficiently, we must be able to think clearly and react Safe Production requires quickly. That is why we must report to work free from the influence of any substance that could impair or impede our work performance, or create an that we report to unsafe working environment. work fit for duty, take To maintain a safe work environment, the Company may require drug and responsibility for our alcohol testing in the following circumstances: post-offer/pre-employment, own safety and look out for cause, post-accident, random or as otherwise provided by applicable for the safety Company policy. All testing will be performed to the extent permitted by of others. applicable laws. WHAT WE DO: WHAT WE DON’T DO: n Report to work fit for duty n Come to work under the Values in Action influence of alcohol, illegal drugs, n Speak up immediately if we see a improperly used medications or coworker who may be under the any other controlled substance Q. influence of alcohol or drugs while I returned to the job site after a n at work Consume or be under the 10-day vacation and saw Shari at influence of alcohol or illegal n Use good judgment when the morning safety meeting. Shari drugs, or abuse prescription or alcohol is served at a Company- was stumbling, had bloodshot eyes nonprescription drugs, during sponsored event, or at and smelled of alcohol. I asked her, work hours, on Company customer or Supplier meetings, “Are you okay?” Shari responded, premises or in Company vehicles, trade association meetings, “It’s nothing. I stayed out too late or while conducting Company conferences or other events last night.” I don’t think Shari is in business offsite any condition to be working and am n Tell our supervisor if we are n Use, possess, purchase or concerned for her, myself and others prescribed a controlled substance sell illegal drugs on Company that she might create an unsafe and are working in a safety- premises, on Company time or work environment. Should I say sensitive position while using Company equipment something? n Use prescription drugs without a valid doctor’s prescription or A. inconsistent with doctor’s orders Definitely. Shari could hurt herself or someone else in this condition. It’s everyone’s responsibility to maintain For more information, please contact your local Human Resources department. a safe work environment. That means reporting to work fit for duty and looking out for the safety of others. Talk with your supervisor or Human Resources representative immediately so he/she can address the issue. Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 13

RESPECT... We treat each other and employee personal information with respect. 14

Protecting Employee Privacy and Information Values in Action FCX respects employee personal information and complies with all applicable laws that protect the privacy and confidentiality of employees’ personal, Q. medical, and financial records and information. We expect employees Last month, I had to take time off who have the appropriate authorization and clear business need to access for a medical procedure. Before I personal information to treat it appropriately. left, my manager, Karen, and I sat We respect the need for a strong work-life balance and the right of employees down to reassign my projects. I to keep personal activities outside the workplace confidential. FCX normally have worked for Karen for years, does not take an interest in personal conduct outside work unless such and she was very understanding of conduct impairs your work performance or safety, or affects the reputation or my situation and said to let her legitimate business interests of the Company. know if I needed anything. After the procedure, I realized my Use of Company-provided equipment, services and time spent on Company recovery was going to take longer property should not be considered private. The Company reserves the than expected, so I spoke with right to inspect and search its facilities and property, including computers, Karen about it. A few days later, vehicles, telephone records, cell phones, lockers, email, Internet usage, some of my coworkers contacted business documents and other workspaces, as well as personal containers me, asking if I was okay. They said on Company property, such as lunch and tool boxes, to the extent permitted Karen told the team about my by applicable law. medical procedure and that, because of my complications, I WHAT WE DO: WHAT WE DON’T DO: would not be back to work for a few more weeks. While I n Treat employee personal n Share or disclose employee appreciate everyone’s concern, I information confidentially and personal information unless didn’t want others to know what with the appropriate safeguards authorized by the employee or was wrong. What do I do? required under applicable law n Restrict access to records containing employee information n Use personal information to those authorized and with inappropriately A. a clear business need for the Talk to Karen. She may have had information the best of intentions when sharing your medical information, but the n Follow all applicable privacy laws Company is committed to and Company privacy policies safeguarding employee personal information, privacy and For more information, please see the Records Management Policy and confidentiality. If you don’t feel MIS End User Policy on FM Web. comfortable talking to her, talk to your Human Resources representative. WHAT EMPLOYEE INFORMATION IS CONSIDERED PERSONAL? Employee personal information can include home address, date of birth, age, race, religion, account numbers and medical records, to name a few. Basically, it’s any information that individuals may not wish to share publicly. Freeport-McMoRan | Principles of Business Conduct 15

INTEGRITY... STRENGTH IN VALUES: We are honest, transparent and OUR COMPANY responsible in all business dealings. As employees of FCX, we are responsible for our actions and decisions. We are honest and transparent in our work and uphold the highest standards when conducting Company business and handling Company information. We communicate openly and accurately both inside and outside the Company. Avoiding Conflicts of Interest We have an obligation to each other, our shareholders and our Suppliers to make all business decisions solely on the basis of sound business judgment. A conflict of interest may occur if we have a bias or personal interest that interferes with our ability to make an objective business decision in the best interest of the Company. This may include: n Outside jobs and affiliations with Suppliers, customers or competitors, or government agencies n Supervising friends or relatives n Having an intimate relationship with another employee for whom you influence decisions, such as salary, performance rating or promotions n Serving as a board member of another organization n Investments, including those of relatives, that might influence or appear to influence your judgment n Giving or receiving gifts on behalf of FCX Conflicts of interest aren’t necessarily wrong or unethical, but it is important that they be identified and appropriately managed. It’s also important to avoid any actions or relationships that create, or even appear to create, a conflict of interest. While it’s impossible to present an exhaustive list of conflicts of interest, the following section provides guidance on some of the areas in which conflicts of interest are most likely to occur. For more specific guidance, refer to the Conflicts of Interest Guidelines on FM Web. 16 Freeport-McMoRan | Principles of Business Conduct

STRENGTH IN We have an obligation to VALUES each other, our shareholders and our Suppliers to make all business decisions solely on the basis of sound business judgment. 17

Values in Action Outside Employment and Activities A conflict of interest may arise if you take a second job working for a customer, Q. Supplier, competitor or government body with regulatory authority over the Company (generally not permitted), or if your outside employment or activities A local charity where I regularly interfere with your ability to fulfill your responsibilities to FCX. volunteer recently offered me a part-time position. I’m very WHAT WE DO: WHAT WE DON’T DO: passionate about the cause and would like to take the job offer. n Disclose all outside employment n Allow any outside employment or Would this be okay, as long as it or consulting opportunities other activities to interfere with does not interfere with my work our job responsibilities n hours? Ensure that outside activities do not interfere with our job n Work for a customer, competitor A. responsibilities or performance or Supplier n Obtain approval from our n Risk damaging the Company’s Maybe. While we encourage supervisor or manager before business or reputation charitable and civic work, you serving on any board or always should discuss an outside advisory board of any for-profit employment opportunity with organization your manager before accepting a position. Personal/Significant Financial Interests Each one of us must be careful that our investments, or those of our relatives, do not impair our ability to make objective decisions on behalf of FCX. Significant financial interest refers to any financial interest that might influence, or might reasonably be thought by others to influence, an employee’s judgment or action when conducting Company business. WHAT WE DO: WHAT WE DON’T DO: n Understand our personal and/or n Own, either directly or indirectly, a significant financial interests may significant financial interest in any create, or be perceived to create, business that does business with a conflict of interest or seeks to do business with FCX n Disclose any significant financial ownership interest in a business that does business with or seeks to do business with FCX 18 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

Relationships with Family and Friends Values in Action FCX recognizes and respects our employees’ right to associate freely and to pursue personal relationships with those we encounter in the work Q. environment. In return, each of us must use good judgment to ensure that I recently was promoted to a new those relationships do not negatively affect our job performance, our ability to position and now have authority to supervise others or the work environment. contract with a Supplier where my father works. His company has Similar situations may occur when working with customers or Suppliers. been a Supplier to FCX for many Conflicts of interest can range from directing Company purchases, leases or years. Does my promotion and sales through a relative or friend; to having input into the review, selection or new role present a potential contract negotiation of a Supplier with whom you have a personal relationship; conflict of interest? to involvement in the hiring or supervision of a relative or friend. WHAT WE DO: WHAT WE DON’T DO: A. n Make decisions objectively n Interview, select, hire or supervise Yes. Even though the company has and act in the best interest of anyone with whom we have a been a Supplier to FCX for many the Company, not our personal personal or family relationship years, your involvement in the interest without discussing it with our decision-making process to select supervisor or Human Resources the Supplier where your father n Disclose to our supervisor any works may create the appearance n family or personal relationships Manage or make decisions of a conflict of interest. You should with those we supervise, sell to or related to Suppliers that we disclose your situation to your buy from know to employ friends or family supervisor or your local Human without supervisor approval n Follow the instructions of our Resources representative immedi- supervisor in dealing with any ately so appropriate steps may be conflict of interest taken to ensure a fair selection. DISCLOSING A POTENTIAL CONFLICT OF INTEREST If you’re in a situation where there might be a conflict of interest, or where there might be the appearance of a conflict: n Disclose your situation to your supervisor or your local Human Resources representative immediately n Remove yourself from any related decision-making process until the conflict is resolved by the Company n Support the Company’s decision Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 19

Values in Action Gifts, Meals, Travel and Entertainment We have many Suppliers who are vital to our success, which is why Q. relationships with Suppliers must be based entirely on sound business Sheila, a planner in our group, decisions and fair dealing. Business gifts and entertainment can build goodwill, recently was given two tickets to a but they also can make it harder to be objective about the person who football game in Chicago, as well as provides them. None of us should give gifts and entertainment to, or accept airfare and a hotel reservation, by them from, any organization or individual if doing so might impair, or appear to one of our fuel vendors as a thank impair, our ability to perform Company duties or to exercise judgment in a fair you for executing a contract. This and unbiased manner. Many departments have specific guidelines about giving sounds like a large gift and a and accepting gifts and entertainment, so be sure to check local site policies, possible potential conflict of interest. as well as the FCX Conflicts of Interest Guidelines, or talk to your supervisor or Should I say something to my Human Resources representative for more information. supervisor? WHAT WE DO: WHAT WE DON’T DO: A. n Base our decisions on sound n Accept gifts or entertainment business judgment when doing so might cloud our Yes. There is definitely a conflict of judgment interest. The cost of the tickets, n Understand our site-specific airline and hotel is well beyond a and/or department-specific n Give gifts or entertainment in nominal value. Accepting gifts like policies on giving and receiving order to exert improper influence this can negatively impact the gifts and entertainment n Accept travel from Suppliers Company’s reputation of dealing n Decline personal gifts from without management approval fairly with Suppliers. You should Suppliers and gifts beyond a contact your supervisor, the contract n Allow customers or Suppliers to nominal value administrator or a Human Resources pay for lavish meals or provide representative so the issue can be n Obtain supervisor approval before meals on a regular basis addressed properly with Sheila and giving gifts to a customer or the Supplier. Supplier beyond a nominal value n Disclose any gift received beyond a nominal value WHAT TYPES OF GIFTS ARE ACCEPTABLE? Barring site- or department-specific policies to the contrary, gifts are generally acceptable, as long as they are not requested or solicited, are below a nominal value, are infrequent, are not cash or cash equivalent, are not given or received in an effort to influence someone, and do not take advantage of our position with a Supplier. Accepting gifts, travel or entertainment during a bidding process is prohibited. COMPETING WITH THE COMPANY None of us should engage in activities that are in direct competition with the Company. We should not benefit personally from business opportunities that we discover through the use of Company property, information or position. Similarly, we should not take personal advantage of information we learn as a result of our position with FCX. 20 Freeport-McMoRan | Principles of Business Conduct

Business gifts and entertainment can build goodwill, but they also can make it harder to be objective about the person who provides them. 21

INTEGRITY… Detecting Fraud Fraud is the intentional act of deceiving or misrepresenting facts for personal We communicate openly gain, or to benefit or cause damage to someone else or the Company. No and accurately, inside company is immune to the risk of fraudulent activity. In accordance with our and outside laws and regulations, it is our responsibility to take appropriate action when the Company. these situations are suspected or may occur. FCX does not tolerate fraud, any coverup of fraud, or the failure to report suspected fraud and will take disciplinary action against these types of activities. Our employees, officers, directors and Suppliers play an important role in preventing, detecting and reporting fraud. You must report all known or suspected fraud, no matter how insignificant the dollar amount or how the issue may appear. For questions about potential fraudulent activity or to disclose fraud, talk to your supervisor, Human Resources representative or local Compliance Officer or contact the FCX Compliance department. Creating and Maintaining Accurate Books and Records A company’s credibility is judged in many ways. One very important way is the integrity of its books, records and accounting. FCX is committed to providing our shareholders with full, accurate, timely and understandable information about the Company’s financial transactions and results of operations in accordance with applicable securities laws. Every one of us, regardless of our position within the Company, has an obligation to make sure that the information we contribute to FCX’s financial records is complete, accurate and timely. We are responsible for the accuracy of all the records we generate and data we input, from individual time cards to inventory reports to corporate balance sheets. WHAT WE DO: WHAT WE DON’T DO: n Carefully follow all Company n Keep off-the-books accounts recordkeeping procedures and n Provide false or incomplete guidelines records, or intentionally omit n Ensure all necessary information necessary information is provided, and is accurate and n Mislead or misinform anyone timely about our finances or business n Provide actual receipts or backup operations documentation when required 22 Freeport-McMoRan | Principles of Business Conduct

Managing Our Records Appropriately EXCELLENCE… Various laws and regulations require FCX to record and preserve business We work with purpose information. Managing our records effectively helps us to make better business decisions and meet our legal, regulatory and contractual obligations. Our to deliver high-quality Records Management Policy and Records Retention Schedule provide results. guidelines and procedures for the retention, proper storage and disposal of records. The Company’s business records include all documents related to its business, regardless of media type. From time to time, a government investigation, an audit or a legal proceeding may require that certain records be held and preserved. You will be advised of the issuance of a legal hold notice. While in effect, a legal hold notice overrides the Records Management Policy and Records Retention Schedule. You should follow the instructions in the legal hold notice until you receive further instructions from the Legal department. WHAT WE DO: WHAT WE DON’T DO: n Carefully follow the Company’s n Destroy, shred, conceal or Records Management Policy and otherwise alter documents or Records Retention Schedule records potentially relevant to a government investigation, an n Store records in approved audit or a legal proceeding (this physical facilities or electronic could lead to criminal or civil repositories to ensure that they liability for the Company and for are secure and accessible to the those involved) business n Dispose of or store any Company n If unsure about a record, always records in a manner inconsistent err on the side of preservation and with our Records Management contact the Records Management Policy department for guidance For more information, please see the Records Management Policy and Records Retention Schedule on FM Web. WHAT ARE COMPANY RECORDS? Company records can include: Company records come in all formats and media, including: n Contracts n Audio or video recordings n Correspondence, including memoranda, letters, email, text messages and attachments n Computer files, databases and email, including attachments n Personnel files n Paper documents, including correspondence, n Policies and procedures engineering drawings, architectural plans, n Production reports charts, records, sketches and maps n Purchase orders and invoices n Photographs, prints and electronic media files n Reports, analyses, maps, drawings, plans, schedules, tables, presentations and financial models 23

INTEGRITY… Protecting Our Confidential Information and Intellectual Property We take responsibility Our strategic thinking, creativity and innovative ideas make significant for our words, actions contributions to the Company’s continued success in the marketplace. We and decisions. must protect and use responsibly our confidential information and intellectual property, which include but are not limited to: n Exploration plans n Business objectives n Unpublished financial information n Computer programs and related documentation n Customer, Supplier and pricing information n Operating plans n Reserve information that has not been made public n Research, processes, formulas and technical data n Trade secrets and patent applications Those who have access to FCX confidential information and intellectual property are obligated to safeguard it from unauthorized access. Any information created during your employment belongs to the Company. RESPECT FOR THE INTELLECTUAL PROPERTY OF OTHERS While we have a responsibility to protect our own Company data, it also is important that we respect other companies’ confidential information and intellectual property. If we have authorized access to customer or Supplier confidential information, we must protect it as we would protect our own. We may, however, access and use publicly shared information, such as presentations or best practices. We need to respect trademarks and copyrighted material and, if using the intellectual property of another, follow all applicable license terms. If you have questions about using intellectual property associated with another company’s patents, you should consult the Legal department. Requesting or accepting the confidential information of another company without consent is prohibited and may have legal consequences. 24 Freeport-McMoRan | Principles of Business Conduct

WHAT WE DO: WHAT WE DON’T DO: n Refer to the Company’s n Share proprietary or confidential Disclosure Policy and get information, except on a approval before releasing any legitimate need-to-know basis FCX confidential information, n Use proprietary information for or third-party information FCX personal benefit or the benefit has received in confidence, of persons outside FCX outside the Company n Provide our password(s) to n Exercise caution when discussing anyone for any reason, except Company business in public as provided by the MIS End places where conversations can User Policy be overheard, such as restaurants, elevators and airplanes Any information n Exercise caution when using created during electronic devices, such as laptops or mobile phones with your employment screens, in public places to belongs to the prevent others from viewing confidential information Company. n Return all Company equipment and proprietary information in our possession if leaving the Company, never taking any papers or other information n Continue to protect FCX propri- etary and confidential information after we leave the Company For more information, please see our Disclosure Policy, External Communications Policy, GSC Policy and MIS End User Policy on FM Web. 25

EXCELLENCE… Protecting Company Assets We all have an obligation to be prudent about spending Company money We take pride in and protect all our Company’s assets from loss, damage, misuse, theft, our work and always unauthorized or improper use, or waste. We also have a responsibility to report do our best. abuse of our property by others to management. Company assets include our physical assets (such as computers, vehicles and equipment), financial assets (money, corporate credit cards), information (nonpublic data about FCX’s business) and intangible assets (such as ideas, designs and intellectual property). Electronic messages also are FCX property when sent or received using any aspect of Company technology or when pertaining to Company business. Email, voicemail, Yammer, instant messages and text messages are a recoverable, forwardable and potentially permanent record of your communications. To the extent permitted by applicable laws, FCX specifically reserves the right to permit Company-approved representatives to monitor, access and review any documents housed in Company systems, and to monitor and review use of the Internet, any communications sent or received using Company electronic communication systems, and telephone records, even after the employee has deleted or erased them. All such documents, data and records are the property of the Company and may be used and disclosed by the Company as it sees fit. Employees should not assume that communications made or documents, data or records stored on the Company’s electronic systems will be private and not be accessed by the Company. WHAT WE DO: WHAT WE DON’T DO: n Use good judgment when using n Remove Company-owned any Company-owned resources property from FCX work locations for personal use without express n Take all reasonable steps to prior approval ensure Company assets, including portable Company equipment n Use Company-paid contractors to (such as a smartphone, laptop perform work at home or for other or vehicle), are not damaged, personal benefit abused, wasted, lost or stolen n Use Company assets in n Carefully compose electronic unauthorized ways or for messages, keeping in mind inappropriate or illegal activity that messages will become a n Use the Company email or permanent record and a reflection computer network to send or of the Company access discriminatory, offensive, n Promptly report any abuse or defamatory, or pornographic misuse of Company assets messages or materials n Knowingly post or transmit any software containing a virus For more information, please see our MIS End User Policy on FM Web. 26 Freeport-McMoRan | Principles of Business Conduct

Employees should not assume that communications made, or documents, data or records stored on the Company’s electronic systems will be private and not be accessed by the Company. USE OF COMPANY COMMUNICATION SYSTEMS While we are at work, we are expected to be fully engaged and not undertaking personal activities. All FCX communication equipment systems, such as our phones and computer networks, are Company property and are intended, like all other Company assets, for business use. The contents of communications over those systems—like email, voicemail, texts and other electronic messages—also are Company property. 27

INTEGRITY… STRENGTH IN VALUES: We are honest, transparent and OUR MARKET responsible when dealing with At FCX, we strive to preserve our reputation as a competitors and company that can be trusted to deal honestly and customers. transparently everywhere we do business. We compete fairly and in accordance with the highest ethical standards and all applicable competition laws. We believe in free and open competition and do not participate in any type of unfair business practices; that is, any type of advertising or soliciting business likely to deceive or prejudice any customer. Promoting Fair Competition The United States, the European Union, countries in the Asia-Pacific region and many other nations have laws and regulations that prohibit agreements or actions among competitors that might restrain trade or reduce competition. Known as antitrust laws in the United States and competition laws or anti- monopoly laws elsewhere, these laws are designed to encourage competition and promote a fair market for doing business. However, these laws are complex, vary from country to country and cause serious legal consequences for employees and companies if violated. It is critical we avoid even the appearance of an agreement to engage in any prohibited activity with a competitor or customer. In addition to specific interactions with competitors and customers, other activities can create the risk of violating competition laws, such as collecting competitive information and benchmarking activities. COLLECTING COMPETITOR INFORMATION AND BENCHMARKING ACTIVITIES It is appropriate for the Company to keep up with competitive developments and to review all pertinent public information about our competitors. However, we cannot attempt through improper means to acquire a competitor’s trade secrets or other commercially sensitive information—such as proprietary or confidential information relating to pricing, production plans, capacity or costs, market share, bids and contract terms, or customers. As good corporate citizens, we engage in group activities related to safety, environmental and human rights issues and similar activities. When benchmarking activities involve competitors or potential competitors, no commercially sensitive information may be shared. 28 Freeport-McMoRan | Principles of Business Conduct

WHAT WE DO: WHAT WE DON’T DO: It is critical we n Limit our contact with competitors n Discuss or enter into an avoid even the agreement with a competitor n Avoid situations where to fix prices, rig bids, divide up appearance of competitors start discussing markets, force another competitor future pricing, competitive or a market out of business, an agreement to initiatives, production or or agree to boycott a customer other commercially sensitive engage in any or Supplier information that might appear prohibited activity to restrain trade n Provide, ask for or trade information with competitors with a competitor n Treat our customers fairly regarding commercially sensitive and equally, and honestly information or customer. and accurately describe what we do or sell n Make false statements or disparaging remarks about our n Exercise caution when competitors or their products participating in trade association, and services joint venture and benchmarking activities, as even casual n Make inaccurate or dishonest conversations can violate claims about our own products competition laws and services n Seek advice from the Legal n Share commercially sensitive department before entering into information with joint venture any kind of agreement with a partners, unless it directly competitor relates to the business of the joint venture For additional information, please see our Fair Competition Guidelines on FM Web. STRENGTH IN VALUES 29

Responding to Inquiries from Investors, Analysts and the Media As a public company, we have the responsibility to comply with laws regarding fair and timely disclosure of Company information, including the requirements set forth in applicable securities laws. We also have a responsibility to ensure that any information about the Company is accurate and complete—free of misinformation or errors—and presented in a clear manner. That’s why it’s important that only authorized individuals speak or provide information to investors, analysts or the media about the Company’s plans, projects, strategies and financial information. External communication with these groups requires careful consideration and expert understanding of legal and media issues. None of us may comment on, or respond to, inquiries or rumors concerning any transaction involving our Company without direct authorization to do so. Authorized spokespersons for the Company include: n For media inquiries—the appropriate Communications department n For inquiries from investors, analysts, the SEC or others outside the Company—our Chairman of the Board, Chief Executive Officer, Chief Financial Officer or the Investor Relations department 30

WHAT WE DO: WHAT WE DON’T DO: INTEGRITY… n Direct all media and investor- n Speak on behalf of the Company related inquiries to the to investors, analysts or the media We communicate appropriate spokesperson without direct authorization openly and accurately, to do so n Politely decline to comment in inside and outside response to inquiries or rumors n Use Company-provided the Company. concerning FCX’s transactions equipment to distribute or intentions information about FCX other than as required by our regular job n Immediately report to the duties appropriate Communications department any actual or n Use Company computers to potential inadvertent disclosure post messages to Internet chat so the Company can take rooms, social media sites, news corrective action groups or any other similar forum—anonymously or under our own name—without direct authorization to do so For more information, please see our External Communication Policy on FM Web. ENGAGING IN SOCIAL MEDIA RESPONSIBLY Social media—networking sites, video/photo sharing, blogs, forums and others—is a very powerful form of communication. Such communication is increasingly being used by consumers, investors and other audiences to share opinions and seek information. If we choose to use social media personally, we do so the right way. To ensure we protect the integrity of the Company, we do not: n Identify ourselves as a Company representative without authorization to do so n Speak or act on the Company’s behalf without authorization n Create the impression that our personal opinions are those of the Company n Disclose sensitive, proprietary, confidential or financial Company information, other than what’s publicly available n Post Company news and/or events in advance of an announcement or press release 31

INTEGRITY… Avoiding Insider Trading We each have access to information about the Company as a result of our daily We take responsibility responsibilities. Often that information, or inside information, is something an for our words, actions investor would consider when making investment or trading decisions. and decisions. Inside information can be about FCX—for example, that we are expanding or reducing operations or about to announce a major change in strategy. It also can be information about a vendor, customer or other third party. While in possession of inside information, we cannot buy or sell Company stock or the stock of our business partners. Similarly, we cannot provide inside information to anyone or even suggest to anyone that it might be a good time to buy or sell Company stock, based on inside information. If you have access to inside information and have questions about making a trade or sharing information, contact a member of the Legal department. WHAT WE DO: WHAT WE DON’T DO: n Prevent inside information from n Buy or sell Company stock based being disclosed to people outside on inside information the Company n Provide inside information to n Follow Company policy for others so they can buy or sell handling, using and disclosing stock (called tipping) our confidential information and n Talk about inside information with intellectual property family or friends, or discuss it in n Only share the information with public or on social media those inside the Company who truly need to know it to perform their job duties n Immediately report any inside information that mistakenly has been disclosed to others For more information, please see our Insider Trading Policy on FM Web. EXAMPLES OF INSIDE INFORMATION Examples of inside information include unpublished: n Company financial results and dividends n Decisions to open, close, expand or reduce operations at a facility n Exploration plans and nonpublic reserve information n Mergers, acquisitions or sales of specific business units 32 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

Adhering to International Trade Regulations INTEGRITY… We are a global company, working in communities around the world. That global We do what we say focus requires us to know and comply with laws that restrict international trade. Trade control laws ensure we follow the foreign policy and national security we will do. objectives of countries in which we operate. Serious penalties—fines, revocation of export licenses, and customs inspections and delays—can apply when these laws are broken. In addition, violation of trade control laws can undermine the stated objectives of our host countries and the Company’s reputation. If your work involves selling or shipping products, technologies or services across international borders, make sure you keep up to date with the rules that apply and check with your supervisor or the Legal department if you are unsure. Some of the activities trade control laws govern include: Export and import controls. These controls are laws that regulate the movement of goods across national borders. They frequently require that we follow specific guidelines, receive the proper approvals, and pay duties and taxes on items being transported from one country to another. Economic trade sanctions. These laws restrict trade with particular countries, individuals or entities. The U.S. and other countries maintain a public list of prohibited countries and restrictions. To ensure compliance, FCX has developed procedures that require regular screening of customers and Suppliers against government lists of sanctioned parties. Illegal boycotts. U.S. law prohibits companies from complying with international boycotts that are not approved by the U.S. government. Any employee who receives a request to participate in a boycott or other prohibited trade practice must immediately contact the FCX Legal department. The Company is required by law to report any requests to participate in, or provide information in support of, an unsanctioned boycott, even if such requests are declined. Money laundering. Money laundering is when individuals or entities move funds obtained through criminal activities through the financial system to hide traces of their criminal origin, or otherwise enter into transactions to make these funds look legitimate. FCX does not tolerate, facilitate or support money laundering. WHAT WE DO: WHAT WE DON’T DO: n Comply with all laws and n Import or export prohibited goods Company policies regarding or information international trade restrictions n Conduct business with and anti-boycott laws sanctioned countries, companies n Report any requests to engage or people in boycotting activity n Report concerns about any payments or the integrity of any customer or Supplier n Ask if we have questions or are unsure about international trade laws Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 33

COMMITMENT… STRENGTH IN VALUES: We are committed OUR STAKEHOLDERS to contributing to the long-term sustainability The natural resources we develop and deliver are the of the environment building blocks of infrastructure, are critical elements and communities where of progress and fuel the global economy. Responsible we work. management of these resources and strong stakeholder partnerships are critical to how we create value and contribute to sustainable development in the countries and communities where we operate. FCX is committed to minimizing and mitigating the adverse impacts of our operations and maximizing long-term benefits for local communities and governments. This means partnering to develop sustainable development programs that address high-priority needs and contribute to their enduring success. It also means a commitment to manage environmental aspects at each operation. To be successful, we know we must proactively and openly engage stakeholders and work together to continuously improve. Our policies and management systems help us do this and will evolve over time. For more information about our sustainability programs and approach, please see the Company’s annual Working Toward Sustainable Development reports on fcx.com. Contributing to Our Communities We recognize that our operations have economic, social and environmental impacts on local communities throughout their life span. Some of these impacts include land use changes and population influx, while others include economic opportunities and development in the areas of infrastructure, health and education. We develop positive relationships in our communities and engage openly and transparently with our stakeholders to operate and grow our business. In each of the areas where we operate, we collaborate with communities to minimize and mitigate adverse impacts and cultivate opportunities to maximize benefits. We maintain formal stakeholder engagement programs near our operations, some of which include foundations, community partnership panels and community investment funds. Our operations use a community grievance management system for recording, processing and responding to community concerns. From integrated malaria control and agri-business programs at PT Freeport Indonesia to water treatment plants in South America, we are partnering with communities to achieve sustainability. 34 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

WHAT WE DO: WHAT WE DON’T DO: To be successful, n Engage openly and transparently n Make decisions impacting we know we must with stakeholders—including communities without engaging employees, community members our stakeholders proactively and and government officials—on n Make commitments to provide issues that could positively or openly engage Company funds or resources negatively impact areas where we without prior approval stakeholders and operate work together n Keep our commitments to build trust within communities to continuously n Implement, in partnership improve. with communities and local governments, social investment programs to address high-priority needs and facilitate local capacity building n Respond to concerns or grievances raised by local communities or other stakeholders n Seek to address and respect the needs, cultures and customs of local indigenous communities near our operations For more information, please see our Community Policy on FM Web. Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 35

RESPECT… Respecting Human Rights Respect for human rights has been a long-standing commitment of FCX. Our We treat each other policy is to conduct our operations in a manner consistent with the United and our stakeholders Nations Universal Declaration of Human Rights, and to align our human rights with respect. due diligence practices with the U.N. Guiding Principles on Business and Human Rights. We promote human rights awareness through engagement with host governments and local communities, as well as providing training to employees and contractors. We have site-specific human rights policies and systems consistent with our Human Rights Policy, in-country laws and regulations, and the Voluntary Values in Action Principles on Security and Human Rights. Our Human Rights Compliance Officers oversee compliance and training, as well as a grievance mechanism Q. for reporting, documenting and following up on all violations of human rights allegations reported in our areas of operation. Roxanne hears that a contracting company working at her site is WHAT WE DO: WHAT WE DON’T DO: forcing its employees to work nonstop to meet a tight project n Treat everyone in and around n Tolerate human rights abuses, deadline. She is concerned this is an our operations with dignity and such as human trafficking; forced, unfair work practice and could result respect compulsory or child labor; and in an unsafe work environment. She unsafe or unfair work practices, n Uphold human rights principles decides to report her concern to the at our operations local Compliance Officer. Did n Report any acts that may violate n Look the other way when we Roxanne make the right decision? human rights see or suspect human rights n Conduct business with partners, violations Suppliers and customers who A. n Retaliate against any employee share our commitment to Roxanne absolutely made the right who in good faith reports a respecting human rights decision. It is everyone’s responsibil- human rights violation ity to ensure a work environment that upholds the Company’s com- For more information, please see our Human Rights Policy on FM Web. mitment to respect human rights and worker safety. Any concerns about human rights violations or unsafe work practices should be reported to the local Human Rights Compliance Officer or through the FCX Compliance Line. 36 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

Protecting the Environment COMMITMENT… We minimize the impact our operations have on the environment by using risk- We strive to mitigate management strategies based on valid data and sound science. This requires that we review and take account of the environmental effects of our activities potential adverse and plan and conduct our operations in a manner that minimizes adverse environmental and social environmental impacts through each project’s life cycle. impacts throughout each project’s life cycle. WHAT WE DO: WHAT WE DON’T DO: n Comply with all applicable n Ignore the inherent environmental environmental laws and risks of our business regulations n Tolerate carelessness in n Maintain environmental environmental matters management systems that are n Falsify information on any ISO 14001 certified or meet an environmental monitoring or equivalent standard sampling reports n Conduct training for our workforce on site-specific environmental conditions and regulatory requirements n Report all environmental hazards or incidents to our supervisor or the site-specific Environmental department For more information, please see our Environmental Policy on FM Web. Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 37

INTEGRITY… Fighting Bribery and Corruption At FCX, our business relationships are based on our core value of Integrity— We are honest, being honest, transparent and responsible. We abide by international and local transparent and laws and regulations that forbid bribery of government officials and others, responsible. including the U.S. Foreign Corrupt Practices Act. No promises or transfers of anything of value shall be made to a government official that are not consistent with our policies and applicable laws, properly authorized according to our internal procedures, properly accounted for, and clearly and accurately identified on the Company’s books and records. If you are asked to make an improper payment or account for a transaction in an incorrect manner, or become aware of any transaction that may involve an improper payment, report it promptly to the designated Compliance Officers. Keep in mind that payments include the offer, promise to pay or authorization of payment, as well as the actual payment or transfer, of anything of value on behalf of the Company to a government official or others. They also include payments to a Supplier who, in turn, is likely to transfer that payment to a government official or others. The Company has a comprehensive anti-corruption compliance program, which includes detailed policies and procedures regarding authorizations and recordkeeping for specific categories of transactions, including travel expenses, charitable contributions, gifts and entertainment, and other payments to governments and government officials. Before you incur any of these types of expenses, please be sure to check our anti-corruption compliance policies, as well as local approval procedures. FCX prohibits facilitating payments with extremely limited exceptions. Facilitating payments are payments made to help ensure that public officials perform nondiscretionary tasks they are supposed to perform as part of their normal job function (such as visa processing, providing utility service and issuing routine licenses or permits to which you are legally entitled). Any facilitating payment must be reviewed in advance by Company Compliance Officers and/or the Legal department. For additional information, please see our Anti-Corruption Policy and Anti-Corruption Guidelines on FM Web. 38 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

WHAT WE DO: WHAT WE DON’T DO: n Contact our local Compliance n Provide anything of value to a Officers before promising, offering government official in an attempt or providing anything of value, to improperly influence a decision including employment offers, n Make payments or offers through gifts, meals and/or entertainment, third parties we could not make to a government official or an ourselves official’s family member n Circumvent the Company’s n Seek and obtain necessary internal controls by seeking approvals in a timely manner required approvals after a n Keep accurate and complete transaction has occurred records so all payments are adequately detailed n Conduct due diligence on all At FCX, our business potential business partners relationships are based on our core CORRUPTION RED FLAGS: THINGS TO WATCH value of Integrity— FOR WHEN WORKING WITH THIRD PARTIES being honest, Prior to entering a business venture, be on the alert if the proposed partner: transparent and n Refuses to sign anti-corruption certifications and guarantees included responsible. in their contract n Lacks the necessary financial means or qualifications to do the job n Has been recommended by a government official n Has a reputation for bypassing normal business channels, particularly in activities involving the government n Requests approval of a significantly excessive operating budget or unusual expenditures n Insists on financial terms that are unduly generous in light of their work Issues that are identified early and approached thoughtfully often can be resolved without jeopardizing our business interests. Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 39

COMMITMENT… Participating in Political Activities Playing an active role in the political process is an important right and We engage in responsibility we all share as citizens of a democracy. FCX encourages opportunities— employees to register, vote and stay informed on political matters important to including political the success of our business and our communities. activities—to maximize If you participate in political activities, you must use your own time and the benefits our resources and make it clear that your actions and political views are your own operations deliver. and not the Company’s. For example, you cannot engage in personal political activities during paid working hours, use Company resources (such as email, phones and meeting rooms) or place political signs in the workplace. The Company recognizes that public policy decisions can greatly impact our operations and future business opportunities. Through lobbying activities, we share information and views on issues of public concern that have an important impact on FCX. Lobbying is aimed at influencing public policy decisions by providing information to elected or appointed officials and their staff, and is strictly regulated by host governments. Only authorized employees may contact government officials and staff, or otherwise direct lobbying activities. FCX does not contribute Company funds directly to candidates for public office, political parties or committees organized to fund candidates. The Company does make contributions to nonpartisan voter registration, education and turnout programs. WHAT WE DO: WHAT WE DON’T DO: n Make it clear that our political n Use Company resources to views and actions are our own support or endorse candidates and not those of the Company or initiatives n Obtain approval from our n Place political signs or similar local Government Relations communications on Company department before engaging in property political activity or lobbying on behalf of the Company 40 Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct

HOW WE UPHOLD THE PBC Investigations FCX takes reports of alleged PBC violations seriously, no matter how the report is received. We strive to review and resolve each issue quickly, thoroughly and as confidentially as possible. We do this at a local level unless we believe the situation requires otherwise. Human Resources matters may be referred to the local Human Resources representative, accounting issues to the local controller and safety issues to the local safety manager. Depending on the situation, investigations may be conducted by the Compliance department, the Legal department or outside counsel. Cooperating with an Investigation Process Anyone making a You may be asked to participate in an investigation of an incident that has been report in good faith reported by a fellow employee or Supplier. Participating in an investigation does not mean that you are in trouble or that anyone has reported a concern or participating about you directly. It just may mean that you were a witness to an event or in investigations may, because of your position, have information required to investigate a reported concern. If you are involved in an investigation, you are expected to involving the PBC cooperate fully, and be truthful, honest and forthright. Failure to do so may result in disciplinary action up to and including termination of employment. will not be subject to retaliation of Disciplinary Actions any kind. FCX is committed to doing what is right, and as an employee, you are responsible for upholding this commitment. This means complying with the PBC, the policies that apply to your job, other Company policies, and laws, as well as reporting possible violations. Failure to do so could result in disciplinary action up to and including termination of employment. Reporting a violation of our PBC, Company policy or the law does not absolve you from accountability for personal involvement in any wrongdoing or work performance. It may, however, be considered as a factor in your favor when reviewing possible disciplinary action. Waivers FCX does not expect to grant any waivers to these Principles of Business Conduct. However, waivers of any provisions for employees, executive officers or members of the Board of Directors may be made only by the Board of Directors or an authorized committee of the Board of Directors. Any such waivers will be disclosed promptly as required by applicable law. All other waivers must be approved by FCX General Counsel. Freeport-McMoRan | Principles of Business Conduct Freeport-McMoRan | Principles of Business Conduct 41

THE IMPORTANCE OF SPEAKING UP Each of us has a responsibility to report suspected violations of the PBC, our WHEN YOU CONTACT THE policies, procedures or the law to the appropriate personnel as quickly as possible. This ensures that any issues are addressed and resolved in a timely FCX COMPLIANCE LINE manner. We have an open-door culture; we all should feel free to openly discuss n You will be connected with a any questions or concerns about the way we conduct business. This open representative who speaks communication is vital to our growth as employees, a team and a company. your primary language. Reporting Possible Violations and Getting Help n The representative will make note of all your information If you ever suspect that a policy has been violated, have a question about and repeat it back to you for a policy or practice, or have a suggestion on how to improve things, we clarification. encourage you to discuss it with your supervisor or local Human Resources representative first. They usually are the best individuals to address issues n You will receive a report quickly and efficiently. number and personal identification number with an If you are not comfortable going to your supervisor or local representatives, estimated time to call back you have other options. for updates. n The more information you When we speak up, we find strength in our values. Speak up immediately can provide, the better. If if something doesn’t feel right or violates, or possibly could violate, the PBC we do not receive enough or the law. information (names, dates, details, etc.), we may not be able to properly investigate No Tolerance for Retaliation your concern. FCX will not tolerate retaliation against any employee for raising a question or n Be sure to check back concern about the Company’s business practices in good faith, or for using the regularly to see if additional FCX Compliance Line or cooperating in the investigation of such a concern. information is needed. Reports made that are knowingly false are prohibited by this Policy. n You will be notified once a thorough investigation has Any employee who the Company determines has engaged in retaliatory been completed and the conduct or knowingly filed a false report may be subject to disciplinary action appropriate action taken. up to and including termination of employment. If you believe you have experienced any retaliation because you raised a question or a concern or participated in an investigation, you should report that concern immediately using one of the methods described on page 43. FCX Compliance Line The FCX Compliance Line is available 24 hours a day, seven days a week. You can remain anonymous if you wish, as permitted by applicable law. Calls are taken by an outside company, and there is no way to track the call or to determine where it originated. Although you can remain anonymous, if we do not receive enough information, we may not be able to properly investigate your concern. 42 Freeport-McMoRan | Principles of Business Conduct

FCX Compliance Line Country Number AT&T Direct® Access Dialing Australia 1-800-239-835 1. Dial the AT&T Direct® Chile 55-281-8326 Access Code for your Finland 0-800-91-7358 country/location - Indonesia 001-803-10-02-1382 http://www.business.att. com/bt/access.jsp Netherlands 0800-023-1027 Peru 0800-77-150 2. At the prompt dial 800-295-6783 Spain ###-##-#### United Kingdom 0-800-051-9072 / 0-808-234-1567 3. The call will be answered in the language selected United States 800-295-6783 Please hold on the line, as Other locations AT&T Direct® Access it may take a few minutes to obtain an interpreter Resources For questions about the PBC, to discuss issues or to report a concern: n Talk with your supervisor n Talk with your local or corporate Human Resources representative n Talk with your local or corporate Legal department n Call or visit your local or corporate Compliance Officer n Contact the Compliance department: - Email compliance@fmi.com n Contact one of our Chief Compliance Officers: - Call +1-602-366-7550 - Email Compliance_Officer@fmi.com n Contact the FCX Compliance Line: - Phone by location; anonymous reporting is allowed, except for Spain1 - https://fcxcompliance.alertline.com n Send information by mail to: Freeport-McMoRan Compliance Department Attn: Chief Compliance Officer 333 N. Central Avenue Phoenix, Arizona 85004 1Spain’s Data Protection Act (Organic Law 15/1999 on the Protection of Personal Data) prohibits anonymous reporting. Freeport-McMoRan | Principles of Business Conduct 43