Freeport McMoRan : Principles of Business Conduct

PRINCIPLES OF BUSINESS CONDUCT

Strength In Values

Our Values

Who We Are and How We Work- Everyone, Everywhere and Everyday

SAFETY

Safety first-for ourselves, our coworkers and our communities.

• We promote safety and health and wellness at our operations and in the communities where we live and work.
• No job is so important and no schedule so urgent that time cannot be taken to plan and perform work in a safe manner.
• Safe production requires that:
• • We report to work fit for duty, take responsibility for our own safety and look out for the safety of others.
  • We follow safety standards and controls and identify and eliminate potential hazards.
  • We have the authority and responsibility to stop work if it is not being performed safely.
  • We promptly report safety incidents.

INTEGRITY

We are honest, transparent and responsible.

• We are truthful and sincere.
• We communicate openly and accurately, inside and outside the Company.
• We do what we say we will do.
• We take responsibility for our words, actions and decisions.

EXCELLENCE

We pursue excellence in our work.

• We take pride in our work and always do our best.
• We promote change, explore new options and challenge accepted practices.
• We collaborate to create and implement innovative ideas and to develop solutions to issues and concerns.
• We work with purpose to deliver high-quality results.

RESPECT

We treat each other and our stakeholders with respect.

• We are courteous to each other and those with whom we engage.
• We value the diversity, ideas, perspectives and experiences of our employees and our stakeholders.
• We make decisions without favoritism or negative bias.
• We embrace a culture that supports the free flow of information and sharing of ideas.

COMMITMENT

We are committed to contributing to the long-term sustainability of the environment and communities where we work.

• We are accountable for our environmental and social performance.
• We strive to mitigate potential adverse environmental and social impacts throughout each project's life cycle.
• We engage in opportunities to maximize the benefits our operations deliver.
• We partner with our stakeholders to build local capacity and self-sufficiency beyond the presence of our operations.

LEADERSHIP MESSAGE	5
OUR RESPONSIBILITIES	6
Leading by Example	6
Suppliers	7
Making Ethical Decisions	7
STRENGTH IN VALUES:
OUR PEOPLE	8
Commitment to a Safe and
Healthy Workplace	8
Valuing Diversity and Inclusion	10
Promoting a Respectful Workplace	12
Ensuring a Drug- and
Alcohol-free Workplace	13
Protecting Employee Privacy
and Information	15
STRENGTH IN VALUES:
OUR COMPANY	17
Avoiding Conflicts of Interest	17
Outside Employment
and Activities	18
Personal/Significant
Financial Interests	18
Relationships with
Family and Friends	19
Gifts, Meals, Travel
and Entertainment	20
Detecting Fraud	22
Creating and Maintaining
Accurate Books and Records	22
Managing Our Records
Appropriately	23
Protecting Our
Confidential Information
and Intellectual Property	24
Protecting Company Assets	26

STRENGTH IN VALUES:
OUR MARKET	28
Promoting Fair Competition	28
Responding to Inquiries from
Investors, Analysts and the Media	30
Avoiding Insider Trading	32
Adhering to International
Trade Regulations	33
STRENGTH IN VALUES:
OUR STAKEHOLDERS	34
Contributing to
Our Communities	34
Respecting Human Rights	36
Protecting the Environment	37
Fighting Bribery and Corruption	38
Participating in
Political Activities	40
HOW WE UPHOLD THE PBC	41
Investigations	41
Cooperating with
an Investigation Process	41
Disciplinary Actions	41
Waivers	41
THE IMPORTANCE OF
SPEAKING UP	42
Reporting Possible Violations
and Getting Help	42
No Tolerance for Retaliation	42
Contacting the FCX
Compliance Line	42
Resources	43

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Leadership Message

Dear Employee,

At Freeport, our values of Safety, Respect, Integrity, Excellence and Commitment are at the heart of everything we do. Our Principles of Business Conduct - titled Strength in Values - guides our team's efforts and clearly defines the standards to which we all are accountable.

It's essential employees at all levels of our organization read, understand and follow our PBC. The core values detailed are what we have built our reputation on as a company and are important to everyone's commitment to doing what's right.

The PBC covers various topics - from workplace safety to conflicts of interest to protecting company assets - and features scenarios to illustrate our values in action. Using it will help you apply our core values to your daily business decisions and interactions.

Another important aspect is our shared responsibility to speak up if something doesn't feel right, knowing the company will not tolerate retaliation of any kind for raising a question or a concern in good faith.

You all play an important role in upholding our culture of doing what's right, so please take a few minutes now to read our PBC. If you have questions or a specific situation, never hesitate to ask. By being better informed, you can make better decisions, and together, we will continue to prosper.

Thank you for all you do each day to make Freeport what it is. I am honored to work with this winning team. Together, we are proudly creating better futures for all.

Sincerely,

Kathleen Quirk

President

Freeport-McMoRan | Principles of Business Conduct

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Each of us has the opportunity to be a leader-at work, at home and in our community.

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:

• Act with honesty and integrity
• Follow the law and FCX policies and procedures
• Treat each other with respect
• Use common sense and sound judgment
• Seek guidance when unsure about the right thing to do
• Speak up when we see a problem
• Cooperate with investigations
• Complete all assigned training

FCX provides employees training on the PBC. 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:

• Demonstrating the highest ethical standards and quality in our work and expecting the same from every team member
• Being proactive and taking steps to prevent problems before they happen
• Encouraging employees to speak up when something is wrong
• Ensuring all employees complete any necessary or assigned training
• Being visibly engaged and proactive in supporting ethics and compliance matters

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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 Business Partner Code of Conduct (Business Partner Code) and ensure their employees working at Company operations or on FCX's behalf understand and follow the Business Partner Code.

We expect our Suppliers to abide by the laws of the countries in which they operate and behave according to the Business Partner Code. All suspected violations of the Business Partner Code should be reported immediately through the resources outlined in the PBC. The Business Partner Code is in addition to, and does not reduce or supersede, any contractual obligations.

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.

WHAT WE DO:

We require Suppliers to:

• Provide their employees with a healthy and safe workplace
• Operate in compliance with all local laws and regulations
• Uphold and follow the Business Partner Code
• Inform FCX of any possible violation of the Business Partner Code

WHAT WE DON'T DO:

• Permit Suppliers to use child labor or forced labor
• Allow any kind of bribe, kickback or other form of personal payoff tied to our business arrangements

• Is it legal?
• Is it consistent with our PBC, values, policies or procedures?
• Can I rationally and honestly defend my decision?
• Would I want to see this published in the news?

For additional Supplier information, please see the Business Partner Code.

Freeport-McMoRan | Principles of Business Conduct

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SAFETY:

We promote safety and health and wellness at our operations and in the communities where we live and work.

Strength in Values: Our People

Our employees are our greatest strength. Ensuring a 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.

Commitment to 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.

FCX provides the training, tools and resources needed for employees to 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 and job-related injuries or illnesses immediately.

Each of us has a responsibility to recognize and report health and safety hazards. If a hazard cannot be eliminated, employees must work together with supervisors and safety staff to ensure that it is effectively controlled. We share information about potential fatal events, near misses, best practices and other safety-related information throughout the Company so we can learn from each other and improve safety practices.

For additional information, please see our Corporate Safety and Health Policy on FM Web.

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. Speak up and stop work if it's not safe or unclear and talk to your supervisor immediately or contact your local Health and Safety representative.

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WHAT WE DO:

• Report to work fit for duty
• Take responsibility for my own and others' safety
• Assess risk and eliminate hazards using specified controls
• Follow all standard operating procedures
• Speak up and stop work if it's not safe or unclear
• Promptly act on unsafe conditions

WHAT WE DON'T DO:

• Begin a job without proper planning
• Take unnecessary risks
• Ignore unsafe situations
• Downgrade the severity level of safety incidents to avoid reporting
• Compromise safety by rushing to complete our work

We commit to work safely and put safety first every day, holding ourselves and others accountable for our actions.

Freeport-McMoRan | Principles of Business Conduct

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Values in Action

1. John, a long-time company employee, recently interviewed for a position in a different department. One interviewer asked "how much longer do you expect to be with the company, and will you have time to continue to advance?" While John answered the questions, he was uncomfortable with the line
   of questioning and felt there was not enough focus on his skills and qualifications during the interview.

Should John say something?

1. Yes. We treat people fairly and do not make decisions based on age. We value a diverse workforce and the individual skills and experiences of our employees. Talk to your supervisor or a Human Resources representative.

Valuing Diversity and Inclusion

The many cultures, perspectives and life experiences of our people are a source of strength at FCX. We are committed to a workplace where everyone feels like they belong, where they are treated with respect and their opinions are valued, and that encourages people to speak up and share ideas. These ideas help drive innovation and operational excellence.

WHAT WE DO:	WHAT WE DON'T DO:
■ Treat each other with respect and are	■ Allow personal opinions of a
courteous to each other and those	person's culture, appearance or
with whom we engage	lifestyle to affect our ability to
■ Seek out and value diverse points of	make smart business decisions
view and the unique contributions of	■ Show favoritism or bias based on
everyone with whom we work	personal beliefs

• Encourage and reward teamwork
• Make employment decisions based on facts and business needs rather than favoritism and bias

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