BHP Our Code English

Our Code
Your guide to living

Our Charter values every day.
Contents
BHP acknowledges 2. Care for our people and planet 14-17
and pays respect to the
Respect human rights 15
Traditional Custodians of Support our communities 16
the lands and waterways Be environmentally responsible 17
on which, or near where,
our company is located
and operates. We pay our
Our Charter 1
respects to Elders past,
CEO message 3
present and emerging.
Our Code matters 5
Our Code applies to you 5
Don’t look the other way, speak up 5-7
Speak up 6
What happens when you speak up? 6
Protecting those who speak up 6
What happens if you breach Our Code? 7
How to speak up 8 3. Work with integrity 18-25
Foster open, constructive government relationships 19
1. Look out for one another 10-13 Manage corruption risks 20

Value supplier relationships 21
A healthy and safe workplace 11
Avoid conflicts of interest 22
Respect for all 12
Manage competition law risks 23
Respect trade control laws 24
BHP Our Code

Our Code 1. Look out for one another 2. Care for our world 3. Work with integrity 4. Protect our company 5. Protect and respect
information
4. Protect our company 26-29
Protect our assets 27

Our Charter Our Purpose We are successful when:
Our purpose is to bring people – Our people start each day
Safeguard our technology, systems and data 28 and resources together to build with a sense of purpose and
Protect our intellectual property 29 We are BHP, a better world. end the day with a sense of
accomplishment.
a leading global Our Values
– Our teams are inclusive and
resources company. Sustainability diverse.
5. Protect and respect information 30-34 Putting health and safety first,
– Our communities, customers
being environmentally responsible
Communicate consistently and truthfully 31 and suppliers value their
and supporting our communities.
relationships with us and are
Respect personal information and privacy 32 Integrity better off for our presence.
Doing what is right and doing
Report truthfully 33 what we say we will do. – Our asset portfolio is world
class and sustainably
Don’t engage in insider trading 34 Respect
developed.
Embracing openness, trust,
teamwork, diversity and – Our operational discipline
relationships that are mutually and financial strength
beneficial. enables our future growth.
Performance – Our shareholders receive
Achieving superior business results a superior return on their
by stretching our capabilities. investment.
Simplicity
Focusing our efforts on the – Our commodities support
things that matter most. continued economic growth
and decarbonisation.
Accountability
Defining and accepting
responsibility and delivering
on our commitments.
BHP Our Code 1

2 BHP Our Code
information
CEO message
Our purpose is to bring people and resources together to build

a better world.
And how we do that, matters.
Our decisions and actions are guided by the values in Our Charter. In fact, it was BHP’s
commitment to these values that was one of the reasons I came to work here nearly two
decades ago.
Our Code of Conduct brings these values to life. It reminds us why values are important and
helps us understand them in practice.
Our Code is not just for employees and contractors. Operating with integrity is everyone’s
responsibility so Our Code applies to you if you work for us, with us, or on our behalf.
We use our values and Our Code to drive the best possible outcomes. They guide our
partnerships with the communities in which we operate all the way through to how we
work with our customers around the world. And we never compromise on these values.
They guide how we create a workplace where everyone, including those we work with,
feel respected and safe to speak up if they see something that might contradict Our Code…
and we won’t tolerate retaliation against anyone who raises a concern.
BHP must be a place where people feel safe and free to contribute their best. But that’s going “We use our values and
to require every one of us to become active bystanders, have difficult conversations, reflect Our Code to drive the
on our own biases and always call out poor behaviours.
best possible outcomes.”
We all have to come together and own this collectively.
I see the commitment from our people every day, and while we will always strive to be better,
this makes me so proud to lead BHP.
Mike Henry
Chief Executive Officer
BHP Our Code 3

Our Code
4 BHP Our Code

information
Our Code
Our Code matters Our Code applies to you Don’t look the other way, speak up
At BHP, our purpose is to bring people and resources Operating with integrity is everyone’s If you think a decision or action is not in line with Our Code
together to build a better world. responsibility so if you work for us, with us, or Our Charter values, please speak up. If you’re not sure,
our Quick Test can help:
Everywhere we operate, we are committed to doing what or on our behalf, Our Code applies to you.
is right and doing what we say we will do. We care as much
We expect you to:
about how results are achieved as the results themselves. Values: does this fit with the values in
That’s why Our Code matters. It helps us deliver on our • read and understand Our Code Our Charter?
purpose and make the right decisions every day.
• complete annual mandatory training on Our Code and
In Our Code, you’ll find clear guidance on how Our Charter any role-specific training that is assigned to you Safety: could this directly or indirectly
values of sustainability, integrity, respect, performance, endanger someone or cause them physical
• comply with Our Code, the Our Requirements standards,
simplicity and accountability can be put into practice. or mental harm?
any BHP policies, statements, standards and commitments
You’ll know how Our Code applies to you and understand and any procedures that apply to your role, and all
what is acceptable – and what’s not – when working with applicable laws of the country in which you’re working Media: if this appeared as a story in the media,
colleagues, suppliers, contractors, customers, governments would I feel comfortable?
• understand Our Code applies to you at site, in offices,
and communities. And while Our Code can’t describe or
when working remotely, in camp or other BHP-provided
anticipate every situation, if you see – or suspect – a breach Law: is this legal and in line with our policies
accommodation, at BHP functions, when travelling,
of Our Code, you’ll know how to raise your concern or and procedures?
and at all times when you are representing BHP
seek help.
• speak up and report any concerns or breaches
For a glossary of terms used within Our Code visit Family: what would I tell my partner, parent,
of Our Code
bhp.com/ourcode. child or friend to do?
• contribute to a culture in line with Our Code.
Conscience: does this fit with my
If you are in a leadership role, we also expect you to: personal values?
• lead by example and role model behaviour that’s
in line with Our Code and Our Charter values Feel: what’s my intuition or ‘gut feel’? Would
• ensure every member of your team understands their I feel comfortable if this was seen, overheard
responsibilities to comply with Our Code at all times or shared with a colleague, leader or stranger?
• foster an inclusive culture where everyone feels safe

to bring their whole selves to work and comfortable to
speak up or ask questions without fear of retaliation Feedback
• respond to concerns promptly and appropriately, record We welcome your feedback and ideas for improving
any concerns in EthicsPoint and maintain confidentiality. Our Code. Visit bhp.com/ourcode.
BHP Our Code 5

Our Code continued
Speak up What happens when you speak up? Protecting those who speak up
When raising a concern or reporting a breach of We treat every report of a potential breach of Ensuring you can speak up without threats,
Our Code, be open, accurate and provide as much Our Code sensitively, respectfully and confidentially. intimidation, harassment, exclusion or humiliation
information as you can. is critical. We won’t tolerate retaliation or allow any
• Once a concern is raised, it’s assessed and triaged form of punishment, discipline or retaliatory action
• If you’re an employee or contractor, talk to your by our Ethics team according to the categories to be taken against anyone for speaking up, intending
line leader, 2Up leader, Employee Relations advisor, set out in the Our Requirements for Business to speak up or being suspected of speaking up, or for
HR Business Partner, Ethics and Investigations, Conduct standard. cooperating with an investigation. You can find more
Compliance or Legal. You can also raise your information in our Speaking up with confidence
• Sometimes, advice, support and guidance may
concern via EthicsPoint. Guidance Note. In some circumstances, you may
resolve the concern. In some matters, our Ethics
• If you’re a community member, former employee, Support Service can also offer an alternative also have legal protection when you speak up. Refer
supplier or vendor, you can speak with your BHP resolution option acceptable to the impacted person. to BHP’s Whistleblower Policy for more information.
contact point, access the community complaints If an investigation is warranted (and guided by the
Anyone involved in retaliatory behaviour is breaching
and grievance mechanism or contact EthicsPoint. wishes of the impacted person where possible),
Our Code and will be subject to disciplinary action.
we’ll review in line with the process set out in the
In certain circumstances, retaliation may also breach
Our Requirements for Business Conduct standard.
whistleblower laws and BHP’s Whistleblower Policy.
• Depending on the nature of the matter reported If you believe you or anyone else may be, or have
and in line with the Our Requirements for Business been, retaliated against for speaking up, report to
Conduct standard, investigations may be performed your line leader, 2Up leader, Ethics and Investigations,
by the Central Investigations Team within Ethics and Compliance, Legal or EthicsPoint.
Investigations, Compliance, a leader, HR/Employee
Relations or an external investigator. Any information you provide will be kept in confidence
to the fullest extent possible, consistent with law
• If you have any concerns during the process, speak
and good business practices. If you’ve disclosed
to your line leader, 2Up leader, Ethics and Compliance
your identity when making a report, this will only
or EthicsPoint.
be disclosed if we’re compelled to by law, if you’ve
consented or if we determine it’s appropriate to refer
the matter to emergency services, law enforcement
or a regulator. If you’ve chosen to make an anonymous
report, we will respect your decision.
Nothing in Our Code, the Our Requirements standards

or any other document or procedure prevents
you from, or requires approval for, reporting to an
appropriate government authority or law enforcement
body, or from seeking legal advice in relation
to your rights.
6 BHP Our Code

information
What happens if you breach Our Code?

Anyone found breaching Our Code can face serious
consequences. Depending on the severity of the breach,
this could include verbal counselling with a line leader or
2Up leader, a verbal warning, written warning, final written
warning and termination of employment. In some cases,
conduct that is a breach of Our Code may also be a breach
of law and carry civil penalties or criminal charges.
Always
• Be open and honest and provide as much information

as possible when raising a concern.
• Observe confidentiality requirements if you are involved
in an investigation.
Never
• Engage in retaliation or detrimental conduct towards

someone because they or someone else has, intends
to or is suspected of speaking up.
• Lie to an investigator
• Take steps to identify an anonymous reporter.
BHP Our Code 7

How to speak up
Ethics and
Investigations EthicsPoint
Line or Compliance
If you have questions about Our Code, speak to your line leader, 2Up leader, Ethics and Investigations, Compliance, Leader
Legal, Employee Relations advisor, HR Business Partner or contact EthicsPoint. Anyone who works with us,
Legal HR business
on our behalf, or is associated with us, can also access EthicsPoint. Team partner
Employee 2Up
Relations advisor Leader
Contact Ethics Point online via www.BHPbusinessconduct.ethicspoint.com or by phone:
Australia and Asia Europe Mexico Free call

Australia Free call Switzerland Free call 001844 763 3254
1800 423 473 0800 562 876 Peru* (country exit code)
China Free call United Free call 1 503 906 8492
1080 0610 0462 Kingdom 0800 0015 314 Trinidad/ Direct
Free call Tobago* 011 61 3 9639 1234
1080 0261 1385 Americas and Caribbean United Free call
Brazil Free call States 1 844 801 7783
India Free call
0800 892 3110
000 800 610 1130
Japan Free call
Canada Free call Africa
1 844 297 4027
0034 800 40 1212 Algeria Collect call*
Chile Free call (country exit code)
Malaysia Free call 1 503 906 8492
123 0020 1359
1800 817 565
Colombia Free call South
Philippines Free call Africa Free call
01 800 915 5860
1800 1852 0032 0800 998 230
Ecuador 1. From an outside line
Accessible on Mobile Smart and SUN Cellular
dial the direct access Guinea* Direct
devices, PLDT fixed lines and payphones
number for your location: 00 61 3 9639 1234
Free call
Ecuador:
1800 8798 9937
1-800-225-528
Accessible via Globe devices Ecuador
Singapore Free call (Spanish Operator):
800 616 7080 1-999-119
2. At the English
prompt dial:
877 281 5508
www.BHPbusinessconduct.ethicspoint.com
8 BHP Our Code

information
BHP Our Code 9

1. Look out for
one another
Our priority is to provide a healthy,
safe, inclusive workplace where
everyone is treated with respect.
10 BHP Our Code

information
A healthy and safe workplace

Ensuring a healthy and safe workplace is our • Report all accidents, injuries, illnesses, unsafe or unhealthy
conditions, incidents, spills or release of materials into the Hypothetical scenario
priority and everyone’s responsibility.
environment to your line leader or 2Up leader.
Q:
I’ve been asked to complete a maintenance
What this means for you • Identify, assess and take steps to control health and
task before the end of the day that is critical
safety hazards according to your site Health, Safety
to ensure our daily production targets are met.
To manage risks to physical safety, you must adhere to and Environment plans and procedures.
The task has a work instruction which requires a
all global and local BHP health and safety standards,
• Speak up to your line leader, or your 2Up leader if you have specific tool be used when carrying out the task
procedures and plans, including the Our Requirements
concerns about your fitness for work or a colleague’s fitness however the tool is not available and my line leader
for Health and Our Requirements for Safety standards.
for work or ability to carry out assigned work safely. has told me to get the job done. What should I do?
To manage risks to psychological safety and well being,
you must not engage in disrespectful behaviours contrary to • Comply with alcohol consumption limits at villages,
A: afety procedures must never be compromised.
S
this Code - these behaviours can cause harm. It is everyone’s when travelling for work, representing BHP or participating
Don’t start the task until a safe system of work is
responsibility to prevent and report workplace-related in a BHP organised event such as a celebratory dinner.
established and you can access the right tools and
injuries, illnesses, hazards, near misses and actual events • Be prepared for emergencies by ensuring you and equipment. If you’re unable to resolve the matter with
in line with these safety requirements and procedures. any visitors are familiar with emergency procedures. your line leader, contact your 2Up leader or a member
If preferred, safety issues and concerns can be reported of the Health, Safety and Environment function.
anonymously via EthicsPoint. • Act on all complaints or warnings raised with you.
Our hypothetical scenarios will help you apply
If you are a leader, you must implement these requirements Never Our Code every day. Scan the QR Code or go to
and ensure supporting systems and processes are in place.
You must also provide an environment where everyone
is encouraged and feels safe to report any threats to their • Undertake work unless you are trained, competent, https://www.bhp.com/our-code-scenario1
own health, safety or security, or to that of others. medically fit, free of alcohol and drugs and sufficiently
rested and alert to do so.
Being fit for work means being able to perform your role • Undertake any work that appears unsafe, including if the
safely. You are required to be alcohol and drug free at required personal protective equipment is not available.
work and comply with applicable alcohol limitations at
accommodation villages and during other work-related • Consume any drugs, be intoxicated or consume more
activities or travel. We may ask you to undergo random drug than the local alcohol limit at a BHP accommodation
and alcohol testing and you must comply with these requests. village, while participating in a BHP organised event
or representing BHP.
If you are concerned about a colleague, please talk to a leader • Take prescribed or non-prescribed drugs without
or contact the Employee Assistance Program. understanding and declaring the impact on your ability
to safely do your job.
Always • Have illegal drugs or property in your possession
on BHP sites.
• Immediately stop any work that appears unsafe or if the • Bring firearms onto BHP premises without an approved
required personal protective equipment is not used. firearms management plan in line with the Our
• Comply with relevant health, security and safety Requirements for Security, Crisis and Emergency
requirements, use all personal protective equipment Management standard and Business Continuity Plans.
provided and help others who work with you to do
the same.
BHP Our Code 11

Respect for all
Harassment, bullying, sexual harassment, you have an obligation to report business conduct concerns • Pursue a romantic or intimate relationship with a trainee,
racism and other disrespectful behaviours can of which you become aware (only naming the impacted apprentice, graduate or intern if you are a people leader
person with their consent) into EthicsPoint. Health and safety or responsible for providing mentoring or training.
cause harm. Our commitment to safety means issues can alternatively be reported via established safety
these behaviours have no place at BHP. The • Treat someone differently for taking or not taking part in
reporting procedures.
industrial activities such as belonging or not belonging
right to work in a healthy, safe, respectful and to an industrial and/or union association.
inclusive environment at all times is enshrined Always • Discriminate against any individual or group based
in Our Charter.
on personal attributes unrelated to job performance.
• Act professionally at all times and treat everyone
We all have a responsibility to contribute to a safe, fair and with respect.
respectful work environment, free from harassment, sexual Hypothetical scenario
harassment and sexual assault, bullying, racism (including • Speak up if you see, hear or experience disrespectful
racial harassment), and discrimination. This applies when behaviour directed towards you or anyone else.
Q: I ’m a maintenance contractor trainee and the
you are at work, travelling, in accommodation villages, • Challenge inappropriate, exclusionary or discriminatory trainer for my crew has been supportive but they’re
online or at work-related events. behaviour, whether it’s intentional or not. now paying more attention to me than others in the
• Make any employment-related decisions, including crew. The other night, they asked me to go back to
What this means for you recruitment, promotion, training, development and their place. I feel very uncomfortable and not sure
remuneration, based on merit according to skills, what to do. I’m scared I’ll lose my traineeship.
You need to understand and demonstrate the standards of
qualifications and capabilities.
behaviour expected of you. The behaviours listed on page 13 It’s not ok for a trainer to try and start a romantic or
A:
are all a breach of Our Code, have no place at BHP and will intimate relationship with any trainee, considering
not be tolerated. Never the power imbalance between you and the trainer.
Talk to your 2Up leader immediately or contact your
Power imbalances in the workplace • Engage in harassment, sexual harassment, bullying, racism Employee Relations advisor, HR Business Partner,
(including racial harassment), or discrimination. Ethics Support Service or EthicsPoint. You can also
We acknowledge that power imbalances can be present talk to a colleague or someone you trust for support
in the workplace and have the potential to be misused • Behave in a way that would be reasonably viewed as
within the business.
to pursue relationships. This is unacceptable, and can offensive, insulting, intimidating, malicious or humiliating,
undermine efforts to create a safe and respectful workplace including making comments about someone’s personal Our hypothetical scenarios will help you apply
Our Code every day. Scan the QR Code or go to
for everyone. As people leaders and those responsible characteristics.
for providing mentoring or training are in a position of • Distribute, display or share any material that could
trust, we expect they will not pursue romantic or intimate https://www.bhp.com/our-code-scenario2
reasonably offend including: pornography; racist,
relationships with those in trainee, apprentice, graduate homophobic, transphobic, sexist or culturally
or intern positions. inappropriate photos, videos, cartoons and social
media content; and any personal information that
Take action does not relate to you found online.
• Take part in or facilitate hospitality or entertainment of an
If you see, hear or experience behaviour that is not in line
inappropriate nature (for example, sexually oriented) or at
with Our Code or does not reflect Our Charter values, please
inappropriate venues, including accepting or facilitating
speak up immediately or afterwards. Be supportive and
gifts which are inappropriate.
provide compassion and encouragement to any colleagues
(employees or contractors) who speak up. If you are a leader, • Make unwelcome requests for a romantic
or intimate relationship with a colleague.
12 BHP Our Code

information
Behaviours that have no place at BHP
Sexual
Racism
harassment
Harassment Bullying and racial Discrimination
and sexual
harassment
assault
An action or behaviour Sexual harassment is an Repeated behaviour Racial harassment is a racial slur, derogatory comment Adverse treatment of
that would be reasonably unwelcome sexual advance, directed towards or unwanted conduct based on race, descent, ancestry, an individual or group
viewed as humiliating, unwelcome request for sexual a worker (or group ethnicity, ethnic origin, nationality, national origin, country based on personal
intimidating or offensive. favours or other unwelcome of workers) that a of origin, colour or status as an immigrant. attributes unrelated
conduct of a sexual nature, which reasonable person, to job performance,
makes a person feel offended, having considered the such as race, gender
humiliated and/or intimidated, circumstances, may Racism, including racial harassment, can appear in a variety identity, sex, age,
where a reasonable person see as unreasonable, of ways. Racist conduct includes racial harassment and origin, ethnicity,
would anticipate that reaction including victimising, other forms of prejudice, discrimination or hatred directed sexual orientation,
A single, one-off incident in the circumstances. humiliating, intimidating at a person based on race, descent, ancestry, ethnicity, intersex status,
of unreasonable or threatening ethnic origin, nationality, national origin, country of origin, gender reassignment,
behaviour that would behaviour. colour or status as an immigrant. transgender status,
be reasonably viewed as Sexual harassment encompasses disability, marital
a range of conduct including Racial harassment can be a one-off comment. It is and civil partnership
humiliating, intimidating
displaying sexually graphic Repeated humiliating important to remember that a racially harassing comment status, religion, political
or offensive is not
images, sexually suggestive or threatening affects not only the target of the comment but also opinion, pregnancy,
workplace bullying,
comments, suggestive or behaviour can colleagues and onlookers. Even if a person genuinely breastfeeding or family
but it could constitute
inappropriate looks gestures constitute bullying. thinks a recipient will understand that a racist comment responsibilities.
harassment. Single
or staring, non-consensual was not meant to be insulting or hurtful, that comment
incidents of harassment
touching or acts of a sexual Consistent with Our may still have an effect on others that is not acceptable
should not be ignored.
nature and sexual assault. Code and Our Charter and will not be tolerated. We will not tolerate
This behaviour is
in breach of Our Code values, our leaders are any form of unlawful
Sexual harassment is not always empowered to lift the Racial harassment and racism more generally are not
and there is a risk the discrimination.
obvious, repeated or continuous. performance of their only overt acts of abuse or harassment but will include all
behaviour might be Unlawful discrimination
While bullying is characterised teams through regular forms of conduct - conscious or unconscious, explicit or
repeated or escalate. against a person
by repeated behaviour, sexual coaching and feedback implicit - that prevent others from participating in workplace
based on personal
harassment can be a one-off that is respectful and life because of their race. Sometimes this can be caused
Reasonable attributes unrelated
incident. constructive. Such by policies and practices rather than the actions of one
management action to job performance,
coaching and feedback individual -- this is often referred to as structural, systemic or
does not constitute is prohibited.
are not harassment institutional racism. BHP is committed to continually seeking
harassment.
or bullying. to understand where structural, systemic or institutional
racism might exist in our business and to taking action to
address it. If you suspect this is occurring, please speak up.
The possible impact of the action or behaviour on the recipient considering all the circumstances (not just the intent of the person using the behaviour) is considered when determining
whether the action or behaviour is bullying, harassment of any kind or discrimination.
BHP Our Code 13

2. Care for people
and planet
As part of our commitment to creating enduring
social value for people, planet and prosperity,
we all have a role to play in respecting human
rights, supporting our communities and
demonstrating environmental responsibility.
14 BHP Our Code

information
Respect human rights

Upholding and advancing human rights and projects, and changes to existing operations and
projects, located on lands traditionally owned by, or under Hypothetical scenario
are critical to the sustainable operation
customary use of, Indigenous peoples and likely to have
of our business. significant adverse impacts on Indigenous peoples. Q: I ’m aware the local Indigenous community has
strong connections to the land on which we operate,
Human rights are basic political, civil, economic, labour, • Consider the connection between environmental but I’m not sure if there is any active engagement to
social and cultural rights and freedoms to which all people sustainability and human rights. If community ensure their significant sites are effectively
are entitled, without discrimination1. We commit to operating resettlement is required, comply with the International identified and managed. I raised this with my
in a manner consistent with the internationally recognised Finance Corporation Performance Standard 5: Land team and they didn’t know if any engagement
human rights and standards as described in our Human Acquisition and Involuntary Resettlement. is happening either. What should I do?
Rights Policy Statement and Indigenous Peoples Policy
• Suppliers are expected to apply our human rights related
Statement. Respecting human rights and contributing A: ngaging with the traditional owners of the land
E
mandatory minimum requirements as outlined in our
to the realisation of rights is critical to the sustainable and managing cultural heritage matters is an
Minimum Requirements for Suppliers.
operation of our business and the right thing to do. integral part of our business. All our assets must
We also respect the role of human rights defenders in • Communicate our commitment to the Voluntary Principles implement a framework for identifying, documenting
upholding civic freedoms and their significant voice in on Security and Human Rights (VPSHR) to any private and managing aspects of cultural significance.
understanding and addressing human rights challenges. security providers engaged or any public security BHP works to obtain the consent of Indigenous
providers you arrange to support BHP activities. communities for projects that are located on lands
What this means for you traditionally owned by, or under customary use of,
Always Indigenous peoples and are likely to have significant
Our Human Rights Policy Statement and Indigenous adverse impacts on Indigenous peoples. If you are
Peoples Policy Statement provide guidance on BHP’s • Raise any human rights concerns via the community unsure whether these requirements are being met
positions and commitments. complaints and grievance process or EthicsPoint. or have any concerns, speak with your line leader or
2Up leader, use the local complaints and grievance
You must consider the human rights and social and • Consider the human rights implications of BHP activities, process or contact EthicsPoint.
community impacts for our operations, tailings storage including across our value chain.
facilities, major projects, new activities in high-risk countries, • Identify and address human rights risks and adverse impacts Our hypothetical scenarios will help you apply
decisions around acquisitions and divestments, and the from the perspective of the person who holds the right. Our Code every day. Scan the QR Code or go to
closure of our sites.
• Undertake due diligence on our suppliers to assess their
https://www.bhp.com/our-code-scenario3
Always comply with applicable laws. Where differences alignment with human rights.
exist between Our Code and local customs, norms, rules or • Ensure human rights concerns and complaints are
regulations, apply the higher standard. Identify, mitigate or investigated and remedied, if appropriate, and the outcomes
eliminate any risks to human rights that may arise through reported to relevant stakeholders.
our activities, including any arising from the activities of our
suppliers and service providers.
Never
• Uphold the commitments as set out in our Indigenous
Peoples Policy Statement and the Global Indigenous • Threaten, punish, discipline, or retaliate against anyone,
Peoples Strategy. This includes working to obtain inside or outside BHP, for raising or helping to address
free, prior and informed consent for new operations a human rights concern.
1. As defined by the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International
Covenant on Economic, Social and Cultural Rights.
BHP Our Code 15

Support our communities
We are committed to building long-term If you are working on our behalf, we expect the same • Engage regularly with suppliers and partners to share
partnerships based on respect, transparency level of respect in your interactions. Familiarise yourself Our Code and implement robust contract management
with our requirements when engaging and working with processes to ensure the respectful behaviours and
and mutual value. host communities. performance of vendors in the communities in which
We seek to understand the interests, concerns and we do business.
aspirations of the communities where we operate and Always
recognise our everyday interactions, activities, behaviours Never
and decisions can impact positively and negatively on our • Respect the cultures and customs of the communities
long-term viability and the social and economic wellbeing and countries in which we operate, as long as they do • Intentionally favour individuals from one political, religious
of those communities. not conflict with Our Code or the law. or ethnic group on the basis of their membership of that
• Engage with respect, honesty and transparency. group. The exception is when such action supports a
What this means for you BHP approved or legally required program of positive
• Take the views and expectations of stakeholders
discrimination (for example, to assist historically
If you are responsible for working with our community into account in decision-making.
disadvantaged groups in the community).
stakeholders, community development projects • Investigate concerns and complaints and report outcomes
or donations, you must read and understand the • Contribute to any religious organisation for religious
back to relevant stakeholders.
Our Requirements Communications, Community purposes on behalf of BHP.
• Obtain any necessary compliance pre-approvals, in
and External Engagement standard. • Implement a community development project that will
accordance with the Our Requirements Communications,
intentionally, or likely replace, take over or destabilise the
All communication with external stakeholders must be Community and External Engagement standard, before
authority of any level of government.
delivered honestly, respectfully and transparently. Engage offering, promising or approving expenditure for a
with people impacted by operations and ensure their views community project, sponsorship or donation on behalf
of BHP. Our hypothetical scenarios will help you apply
(including vulnerable and disadvantaged groups) are taken Our Code every day. Scan the QR Code or go to
into consideration when making business decisions. • Contact Compliance for advice if you have any concerns
about the legitimacy of a proposed community project,
If you are engaging with Indigenous or First Nations sponsorship or donation, or contact Ethics and Investigations https://www.bhp.com/our-code-scenario4
stakeholders, complete the necessary culture awareness if you have an undisclosed potential conflict of interest.
training and engage in a manner which respects the rights
of Indigenous Peoples as set out in our Indigenous Peoples
Policy Statement.
If people raise concerns or complaints during your

engagements with community stakeholders, record these
in line with the relevant asset complaints and grievance
process. If the concerns or complaints allege a violation
of human rights or other conduct in breach of Our
Code, record the concern in EthicsPoint. If a community
investment (donation, project or sponsorship) is being
considered, undertake due diligence on the recipient
organisation(s) and obtain pre-approval before confirming
any partner or agency to implement a program as per the
Our Requirements Communications, Community and
External Engagement standard.
16 BHP Our Code

information
Be environmentally responsible
Our environmental performance and Those who work with us are encouraged to actively • Undertake work that has the potential to impact on
management of environmental impacts contribute to improving our environmental performance the environment unless you are trained and competent
and comply with our environmental requirements, including to do so and controls are in place to minimise
is an important part of our contribution at an Asset level. Refer to the Our Requirements for environmental impacts.
to social value. Environment and Climate Change standard or speak to
• Engage contractors, suppliers, customers or joint venture
your primary BHP contact for more information about our
We recognise the importance of a healthy environment and partners without an assessment that takes into account
environmental requirements or any suggestions you have
steward a nature-positive approach to the management, their environmental and community impacts, risks,
on how we can improve environmental stewardship.
conservation and restoration of land, water and biodiversity. controls and performance.
Our environmental responsibility is to understand and avoid
or minimise environmental impacts and contribute to the Always Hypothetical scenario
resilience of, and positive impact to, the natural environment
at every stage of our operations.
• Immediately stop any work that may contribute to ur waste is disposed off-site by a licensed waste
O
Q:
Our role in responding to global challenges is set out a significant environmental or community event such facility that is audited by our regulators. Do I also
in our position statements on Climate Change and as an accident, incident, spill or release of material. have to review their performance?
Water Stewardship and our approach to environmental • Report any actual or potential impact to the environment
management in the Our Requirements for Environment A: es, you should review the performance of all
Y
or communities from an environmental event to your
and Climate Change standard. We also have company-level suppliers to ensure they manage their environmental
line leader or 2Up leader (don’t assume someone else
public environmental targets and longer-term goals for performance appropriately. Direct, indirect and
will report).
water, biodiversity and greenhouse gas emissions cumulative environmental impacts and their
• Identify, understand and comply with any environmental associated risks and controls need to be assessed
and report publicly on a range of indicators in metrics,
and regulatory requirements that relate to your work, by BHP. This includes environmental impacts
which are available on our website.
including any land disturbance, water, air, biodiversity, associated with our direct operational activities,
We identify, assess and control risks in accordance with dust, noise and waste management requirements. impacts from others as a result of activities on
the Our Requirements for Risk Management standard • Identify, assess and take steps to avoid and minimise which our operations rely and impacts from others
and work in partnership with others to contribute to adverse environmental impacts associated with that may increase the severity of our own impacts.
a resilient environment. your work and take opportunities to improve
environmental performance. Our hypothetical scenarios will help you apply
What this means for you • Encourage those who work with us and our customers
to minimise their environmental impacts and take

You must understand the potential environmental risks, https://www.bhp.com/our-code-scenario5
opportunities to improve performance.
threats and opportunities, of the tasks you perform in
accordance with the Our Requirements for Environment
and Climate Change standard. You must also understand Never
environmental regulatory requirements relating to the
tasks you perform and look at ways to avoid, minimise • Operate in a location or way that is not in accordance
and rehabilitate impacts to air, water, land, cultural values with the Our Requirements for Environment and Climate
and biodiversity, including greenhouse gas emissions. Change standard, local regulatory requirements, or site
Where actual or potential environmental events occur, environmental procedures.
including non-compliances with environmental regulatory
requirements, you must report these in BHP’s Event
Management system, regardless of severity.
BHP Our Code 17

3. Work with
integrity
We care as much about how results
are achieved as we do about the
results themselves.
18 BHP Our Code

information
Foster open, constructive government relationships

Our ability to conduct business is directly
Always Never
affected by government decision-making.
We regularly share information and opinions • Be truthful, accurate and cooperative when dealing • Authorise, offer, give or promise anything of value
with governments on issues that affect our with government officials and comply with all laws directly or indirectly to a government official to influence
operations and our industry. and regulations. official action.
• Speak to Corporate Affairs before you engage with • Attend an event or activity during work hours or on
What this means for you government officials or their representatives on public behalf of BHP which is intended for political fundraising.
policy or issues that could impact BHP’s reputation
Always act with integrity and maintain honest, transparent • Present information or an opinion to a government
or licence to operate.
relationships with governments and their agencies, officials on behalf of a business partner that is associated
and personnel. • Speak with Corporate Affairs or Compliance (as required with a foreign government without first talking to
by the Our Requirements Business Conduct standard) Corporate Affairs.
• If you are engaging with governments on matters other before engaging on behalf of BHP with government or
• Attempt to obstruct the lawful collection of information,
than of a routine regulatory nature, speak with your regulators regarding government inquiries or regulatory
data, testimony or records by appropriately authorised
Corporate Affairs representative before proceeding. investigations, and before issuing notifications on behalf
government or regulatory officials or hinder the lawful
• Before making a submission to government on behalf of BHP to regulators.
and proper provision of such information by another
of BHP, including responding to government inquiries • Consider potential corruption risks when dealing with employee.
or papers on proposed legislative reforms, obtain approval government officials.
• Take retaliatory action against anyone who lawfully
from Corporate Affairs.
• Seek approval for involvement in any business-related and properly cooperates with government agencies.
• Before submitting an official BHP response to an event or activity organised by, or on behalf of,
• Accept information about a government’s competitive
anti-corruption, competition, sanctions, state secrets a political party or candidate and be transparent
selection of a supplier or competitor’s bid or proposal
or financial markets enforcement agency, obtain when undertaking such activities.
(unless the government has specifically and lawfully
approval in line with the Our Requirements for
• Discuss with your line leader and 2Up leader and authorised the release of the information).
Business Conduct standard.
advise in writing if you plan to seek or accept a role
• Use, or allow others to use, any BHP information, assets
• Before participating in events or activities organised by in public office.
or resources (including donations or sponsorships)
a political party, politician, elected official or candidate
for a political campaign, party or candidate, elected
for public office, obtain approval in line with the Our
official or any of their affiliated organisations.
Requirements for Business Conduct standard. Your
participation in these events or activities must be for • Pay wages or salaries, fringe benefits or remuneration
business, related to policy briefing and supported by your of any kind to a BHP employee working for a political
line leader, and cannot be related to political fundraising. party or candidate during normal working hours.
• Exercise care in situations where a perception
could arise that BHP is sharing information or opinions Our Code every day. Scan the QR Code or go to
with a government on behalf of, or in coordination
with, a business partner that is associated with
a foreign government.
• Notify your line leader or 2Up leader if you wish to
participate as an individual in the political process,
including running for political office. Record in the
Conflict of Interest register.
BHP Our Code 19

Manage corruption risks
Bribery and corruption are prohibited in • regardless of value, not be offered or provided with • Offer, promise, give or approve schemes or arrangements
our business. a frequency which could reasonably be seen as which give an improper benefit to anyone.
being intended to improperly influence any person
• Establish a hidden or incorrectly recorded fund for
We do not engage in bribery or corruption of any kind. • not be capable of causing reputational damage to BHP. prohibited payments.
Everyone who works for us, with us or on our behalf
(including partners and suppliers) must comply with • Use personal funds, divide payments into smaller amounts
You must also get pre-approval for engaging a supplier
anti-corruption laws and no-one has the authority to to avoid approval thresholds, or hide activity which would
who will interact with others on our behalf, offering to
waive these requirements. Where anti-corruption laws otherwise need pre-approval.
undertake a community donation or project, or offering
are not respected, criminal and civil penalties (including to sponsor an event. • Use a supplier if you are concerned they will engage
a term of imprisonment) can apply. Any concerns in corrupt or improper conduct on our behalf.
regarding corruption must be reported immediately.
Always • Deal with a party that refuses to disclose its true identity
(including details of company beneficial ownership).
What this means for you • Immediately report any corruption concerns.
You must not authorise, offer, give or promise anything • Understand the identity, role and interests of the person Hypothetical scenario
of value, directly or indirectly (for example, through or business who you are dealing with (including the
a third party), to anyone to influence them in their role, beneficial ownership of companies). I speak regularly with a government official who
Q:
or to encourage them to perform their work disloyally is responsible for making decisions that will affect
or improperly. You must not request or accept anything • Gain pre-approval before offering or giving anything
BHP. His son has recently graduated with first class
of value, directly or indirectly, to improperly influence of value, according to the thresholds in the
honours from university at a location where we
you in your work for BHP. Our Requirements for Business Conduct standard,
have an office and wants to find a job so he can
or for commercial sponsorships and community donations
You should never make payments of any size to government stay in the country. The official has enquired if BHP
or projects.
officials to facilitate routine services that are legally available. has any jobs and whether I can do anything to help
• Provide accurate and complete information when his son.
However, a payment made to protect the health or safety
seeking pre-approvals.
of an employee, contractor or someone with them who is
A: job is something of value and the son is a close
A
imminently threatened by a third party, is not a facilitation • Record all transactions accurately and in reasonable detail
relative of an influential government official. Given the
payment. If you do make a health and safety payment, to reflect their true nature.
official is currently making decisions which will affect
report it to Compliance as soon as possible.
BHP, this could be used or misinterpreted as
The Our Requirements for Business Conduct standard Never a form of bribery and could constitute a breach of
sets out details of when you must obtain pre-approval to anti-corruption laws. The official’s son can apply
offer or provide something of value to an external person. • Offer, promise, give or approve anything of value of any for advertised jobs and his application will be
In all cases, items must: kind to a government official (including a political party, assessed on its merits in the same manner as any
elected official or candidate for public office or a person other job application. For further guidance, contact
• only be offered or provided for a legitimate our Compliance team.
who holds or performs the duties of an appointment,
business purpose
office or position created by tradition, custom or
• not be offered or provided to improperly influence convention) to influence official action. Our hypothetical scenarios will help you apply
or reward action Our Code every day. Scan the QR Code or go to
• Award business to a company owned by a government
• be legal under local laws official, their relatives or associates in exchange for
• be of appropriate value and nature considering local a benefit to you or BHP.
customs and law, the position of the recipient and
the circumstances
20 BHP Our Code

information
Value supplier relationships

We value our relationships with suppliers the supplier, or potential supplier’s, integrity or ability to
perform the contract, address these issues immediately. Never
and aim to have an effective and streamlined
supply process. Always ensure the supplier (including their beneficial • Use suppliers who breach, or do not meet,
owners): is reputable, competent and qualified to perform our Minimum Requirements for Suppliers.
Suppliers who act illegally or unethically can significantly
the work for which they are being hired; will operate safely
impact our reputation and potentially expose BHP and our • Ignore warning signs that a supplier may be engaging
and ethically; and that compensation sought is reasonable.
employees to criminal and civil penalties. We only seek in inappropriate behaviour.
Take steps to monitor and assess the supplier’s performance.
to work with suppliers who are willing to adhere to similar
This will require, at a minimum, carefully checking Service • Award or influence the award of business to a supplier
values as our own.
Entry Sheets and invoices and raising queries with the you have a direct or indirect financial interest in or who
We use fair and equitable procurement process which aim supplier about any unclear or excessive charges. Always is in anyway associated with a close relative or with
to clearly inform potential suppliers of our expectations inform suppliers where they can access Our Code so they whom you have a personal relationship.
and standards and the requirements applicable to them. understand our expectations of them. • Suggest or directly request a personal gift, hospitality
We encourage our suppliers to be transparent on matters or anything of value from a supplier.
important to society, including on their beneficial ownership.
• Commit BHP by signing a supplier’s contract or any
Always supplier documentation unless you are authorised
What this means for you as per BHP Powers of Attorney to do so.
• Speak up about any activity by a supplier that is • Give one supplier’s confidential business information
If you are required to source goods or services on behalf
inconsistent with Our Code. (for example, proposed rates or winning bid information)
of BHP, always be careful when choosing a supplier and
encourage them to uphold our standards and contribute • Ensure suppliers are reputable, competent and qualified directly or indirectly to another supplier.
positively to our reputation in line with Our Charter. to perform the work, will operate safely and ethically and • Approve a purchase requisition that does not meet BHP
compensation sought is reasonable. requirements or expectations.
Only engage suppliers who share our commitment to:
• Seek approval to engage high-risk suppliers in • Allow a representative of a supplier to approve a
• lawful business practices accordance with the Our Requirements for Business Service Entry Sheet or invoice for that supplier.
Conduct standard.
• high standards of business conduct • Knowingly enter into any fraudulent or otherwise illegal
• Ensure a valid purchase order has been received by transactions or fail to report them as soon as you suspect
• management practices that respect the rights
the supplier before they start work or provide goods or such arrangements may exist.
of all employees and local communities
services, and that agreements clearly state the goods or
• minimising impacts on the environment services to be provided, the basis for earning payment • Award business to a supplier who would present a
and the rate or fee. corruption risk or who refuses to disclose their beneficial
• providing a safe and healthy workplace
ownership to BHP as required.
• our Minimum Requirements for Suppliers. • Conduct regular reviews of supplier relationships
and performance in line with the Our Requirements
Always source goods or services in accordance with the Contractor Management standard. Our Code every day. Scan the QR Code or go to
Our Requirements for Supply and Our Requirements for • Verify that Service Entry Sheets or invoices clearly
Legal Services, Contracts and Disputes standards and the and fairly represent goods and services provided. https://www.bhp.com/our-code-scenario8
relevant Procurement Functional Level Requirements (FLRs). Raise queries about unclear or excessive charges.
Conduct a health and safety risk assessment before any • Make payments only to contractual counterparties
sourcing process and ensure commercial decisions do not that actually provide the goods or services.
compromise health and safety. If there is any doubt about
BHP Our Code 21

Avoid conflicts of interest
Every decision we make should be in the best If you’re a leader of someone who has an actual, potential
or perceived conflict of interest: Hypothetical scenario
interests of BHP and free from personal bias.
Conflicts of interest, whether actual, potential or perceived, • ensure the details are documented in the Conflict of Q: y partner’s consultancy specialises in an
M
must be appropriately disclosed and managed. A conflict Interest register area where BHP needs advice. Can I recommend
of interest can arise when your interests or activities affect, • agree, document and implement an appropriate course their business?
or have the appearance of affecting, your judgement, of action that removes or manages the conflict
A: ou can make the team aware of your partner’s
Y
objectivity or independence. This could include (but is
• monitor and regularly validate adherence to the agreed connection to the business, however, you should
not limited to):
course of action be completely transparent about your interest so
• pursuing, awarding or maintaining BHP business Procurement’s processes can be independently
• adjust the documented course of action as required.
opportunities for personal gain or the benefit of close applied. Discuss the recommendation with your line
relatives or friends leader, ensure the details are registered in the Conflict
• holding outside jobs or affiliations, including directorships
Always of Interest register and that a suitable plan to manage
this potential conflict of interest is put in place.
• holding investments in businesses that are suppliers
• Excuse yourself from any decision-making process where
to BHP or which BHP has or may invest in
you have an interest that could influence your ability to Our hypothetical scenarios will help you apply
• receiving money, property, services or gifts, hospitality or make an objective decision. Our Code every day. Scan the QR Code or go to
entertainment from suppliers or other third parties doing,
• Report all actual, potential or perceived conflicts of interest
or proposing to do, business with BHP
in the Conflict of Interest register. https://www.bhp.com/our-code-scenario9
• being in a close personal relationship with someone in
your reporting line, including a close relative, or a romantic
or intimate relationship.
Never
What this means for you • Hire, promote or directly supervise a close relative,
or use businesses of close relatives unless this has
Avoid business and personal dealings that create a conflict been specifically authorised via the Conflict of
of interest or a potential or a perceived conflict of interest, Interest register.
even if you don’t think there is one. Conflicts can also arise • Appoint or award business to any party that you are
during the course of a normal business relationship due to personally or financially associated with.
a change in circumstances.
• Misuse BHP resources (including information) or your
Report all actual, potential or perceived conflicts of interest position of influence at BHP to promote or assist an
in the Conflict of Interest register. external activity or party.
• Interfere in the fair and transparent operation of bid
Reject offers of travel and accommodation from or tender activities.
external parties. If there is a valid business purpose to
attend an event or function, BHP will pay for travel and/or • Accept gifts, hospitality, entertainment or other favours
accommodation costs. or benefits from anyone you are evaluating in a bid or
tender with BHP.
22 BHP Our Code

information
Manage competition law risks

We are committed to full compliance with
Always Never
competition laws.
Competition laws promote fair competition and prevent • Maintain BHP’s independence in dealings with third parties, • Agree with a competitor to fix, raise, lower or stabilise
a range of practices that restrain trade or restrict free including in relation to pricing, marketing and selling. prices of goods sold or purchased, including in relation
and fair competition, including price fixing, market sharing, to recruitment activities, such as employee salaries
• Consider the appearance and implications of interacting
bid rigging or abuses of a dominant position. A breach and benefits.
with a competitor or potential competitor, whether in
of competition laws may result in serious consequences a business or personal setting. • Agree other competitive terms with a competitor
for you and BHP, including fines and imprisonment. such as pricing formulae, discounts, margins, rebates,
• Avoid any action which could imply illegal coordination
commissions or credit terms.
with competitors or potential competitors.
What this means for you • Limit production or agree with a competitor to reduce
• Ensure written communications are clear and accurate.
or limit production capacity.
To ensure you do not breach or appear to breach • Obtain approval pursuant to the Our Requirements
competition laws, contact Compliance or Legal: • Rig a bid or otherwise illegally coordinate bidding
Business Conduct standard before submitting any
or tendering activities.
• before exchanging competitively sensitive information, information on behalf of BHP to a competition authority.
directly or indirectly, with a competitor or potential • Allocate markets, customers, suppliers or geographic
• Comply with joint venture ring fencing protocols.
competitor territories with a competitor.
• Consult with Compliance or Legal before accusing a third
• before joining an organisation involving competitors • Agree with a competitor to boycott any customer
party of anti-competitive behaviour.
or potential competitors or supplier.
• when potentially inappropriate contact is initiated • Obstruct a competition authority by providing false or
by a competitor or potential competitors Our Code every day. Scan the QR Code or go to misleading information, preventing a legitimate onsite
investigation, concealing or destroying documents
• when considering new cooperation arrangements with
or alerting any third party to the fact of a competition
a competitor or potential competitor, including joint https://www.bhp.com/our-code-scenario10
law investigation.
production, joint procurement, joint marketing, and
shared logistics
• when a complaint is made about the competitive
behaviour of BHP
• when you suspect a third party is acting in an
anti-competitive manner towards BHP
• if you are contacted by a competition authority.
If you suspect an employee, contractor or third-party

may be engaging in anti-competitive behaviour report
it immediately.
BHP Our Code 23

Respect trade control laws
International trade is critical to our business. If you become aware of any suspicious transaction
(such as a transaction which does not make economic Never
We respect the international trade laws that govern our sense or which seems overly complex), notify
transactions and comply with all applicable trade control Compliance immediately. • Undertake any business activity with a party that is
laws, including export controls that impose restrictions of sanctioned or owned by or operating from a sanctioned
licensing requirements on exports of goods or technology, country or territory without prior approval from Compliance.
trade and financial sanctions that prohibit or restrict
Always
• Proceed with a business transaction without prior approval
transactions with certain individuals, entities, vessels, from Compliance if there is any doubt as to whether the
countries or regions, and anti-boycott laws. Our systems • Follow BHP due diligence requirements for suppliers,
transaction might breach trade control laws.
screen suppliers and customers to prevent unauthorised customers, vessels and any other third parties with whom
transactions. We also seek to ensure our activities do not we transact. • Conceal the true identity of the counterparty or other
facilitate money laundering or terrorist financing. relevant facts of a transaction, or otherwise take any action
• Obtain any necessary export control licences or approvals
to evade or avoid trade controls restrictions.
before proceeding with a transaction.
Governments implement trade control laws to support their
foreign policy and national security objectives. If we are • Understand the intermediate and ultimate destinations of Our hypothetical scenarios will help you apply
involved in a transaction that breaches or is inconsistent goods, software, technology and other items or associated Our Code every day. Scan the QR Code or go to
with these laws, it may expose BHP and our employees technical assistance we provide to third parties, and the
to criminal penalties (including imprisonment) or civil source (including country of origin and country of export) https://www.bhp.com/our-code-scenario11
penalties, sanctions or other consequences, and could of goods, services and other items that third parties are
cause significant damage to our reputation and interruption providing to us.
to our business. • Understand whether your customer is on-selling
BHP commodities. Obtain assurances that such goods
What this means for you are not being on-sold to sanctioned parties, countries
or territories.
You must always comply with trade control laws. With trade
• Investigate any trade controls red flag in a transaction and
controls programs subject to frequent change, ensure
do not proceed with the transaction until the issue has
you follow our onboarding and due diligence processes
been resolved.
whenever you transact with a third party. If you become
aware of any activity involving BHP and any sanctioned party, • Promptly notify Compliance of any suspected boycott
or sanctioned country/territory or their residents, entities, requests received, and any third-party or government
or government, contact Compliance immediately. inquiries or communications related to compliance with
trade control laws and regulations and await guidance on
If you are involved in exporting, you must be familiar with how to proceed.
export licensing requirements. The Our Requirements for
Business Conduct standard provides initial guidance. If you
are unsure, seek assistance from Compliance.
If you are asked to withhold goods or services from a party

for boycott-related reasons, contact Compliance. Keep in
mind these requests may be included in contract clauses,
requests for proposal, purchase orders, letters of credit or
other documents, or may even be made orally.
24 BHP Our Code

information
BHP Our Code 25

4. Protect our
company
If you work for us or on our behalf, you have
an obligation to protect BHP’s property and
respect intellectual property rights.
26 BHP Our Code

information
Protect our assets

We all have an obligation to protect BHP’s
Always Never
assets and use them for their intended purpose.
Assets include physical and non-physical • Use our assets for their intended purpose. • Use BHP’s assets for personal gain.
property such as equipment, inventory,
• Protect our assets from waste, damage, misuse, • Take physical property or information assets belonging
technology, money, intellectual property interference, unauthorised access, modification to BHP for personal use.
(IP) and company information and data. or disclosure loss, fraud and theft.
• Transfer BHP data or information outside of BHP systems
Competitively sensitive and proprietary information • Report any potential waste, damage, misuse, loss, without prior approval from your line leader and/or
are also considered assets. This includes: fraud or theft of our assets. information owner.
• operational data, such as production and maintenance • Prevent unauthorised personnel from accessing our • Enter into any fraudulent or illegal transactions or fail
data, master data and data related to our equipment facilities, information, data or other assets, where to report any fraudulent activity.
sensors and process control systems possible and safe to do so.
• Take any action that undermines the integrity of vendor
• strategic and marketing plans • Report suspicious emails, text or calls to Cybersecurity. or customer data in our systems.
• information used in trading activities • Immediately report actual or suspected ransomware • Permit unauthorised entry to a BHP site or office,
• research and other technical data. or cyber extortion incidents to Cybersecurity. or access to our information technology.
• Refer to data retention and disposal schedules in • Ignore security complaints or an inadequate security
What this means for you the BHP Data Catalogue before disposing of data. procedure that may present threats to our people
or assets.
You are responsible for appropriately using and safeguarding • Follow the Our Requirements for Information
BHP’s assets. You are also expected to respect the physical Governance and Controlled Documents standard
and non-physical assets of others, and never knowingly when creating, capturing or managing information. Our Code every day. Scan the QR Code or go to
damage or misappropriate those assets including
information and technology. https://www.bhp.com/our-code-scenario12
You are expected to capture or create data that meets our

data quality standards. If you’re not sure of the standards,
refer to the BHP Data Catalogue.
Never share confidential information or competitively

sensitive information without authorisation from your
line leader. If unsure, ask your leader, 2-Up, Ethics and
Investigations, Compliance or Legal.
We are all responsible for protecting BHP’s assets and

this includes preventing and detecting fraud. Fraud is any
deliberate act of deception which is undertaken for personal
or third-party gain, and which may result in financial or non-
financial loss to BHP or another party. Examples may include,
but are not limited to, making false statements or falsifying
documents to obtain a personal commission or award,
misusing BHP’s information for personal advantage
or physical theft.
BHP Our Code 27

Safeguard our technology, systems and data
Safeguarding our technology systems and Never use, modify, transfer, publish, share, remove or
delete BHP data or intellectual property without written Never
data is the responsibility of everyone who
authorisation from your line leader.
works for us or on our behalf. • Divulge your BHP system, devices or application
Moderate personal use of BHP technology is permitted, passwords or allow anyone else to gain access to BHP
Inappropriate use of technology or data may expose our
provided you comply with the above requirements. technology and systems using your login credentials.
company to risks and vulnerabilities, including viruses,
ransomware attacks, security breaches, theft or loss of • Leave BHP technology or mobile devices unattended
BHP property and more. This could result in financial loss, in public places.
legal impact or reputational damage. Always
• Engage in fraud, commit a crime online or fail to report
a fraud.
All BHP hardware, software and data is the property of • Follow the Our Requirements for Technology and
BHP. This includes BHP data stored on personal and BHP • Install software on or connect hardware to BHP devices
Cybersecurity standard and our Social Media Policy
devices. To mitigate risk and comply with relevant laws, without authorisation from Technology.
when using BHP’s technology, systems and data.
regulations and standards across the global locations in • Deliberately access, store, send, post or publish
which we operate, the use of BHP technology and systems • Treat emails and other electronic forms of
inappropriate material, or ignore these activities
is monitored, reported and, where required, blocked without communication as official records. if you know of others doing so.
prior notice. Data stored on BHP technology and systems • Use authorised applications for business • Access applications or systems for which there is no
may be accessed, reviewed or disclosed for the purposes communications or to conduct business activities. business justification.
of maintenance, business needs or to meet legal, regulatory
• Ensure your personal and corporate devices have • Use unauthorised applications (such as WhatsApp,
or policy requirements.
the latest security updates – do this by connecting WeChat) for documenting or agreeing business
BHP devices to our corporate network at least once transactions. See our Social Media Policy for details.
What this means for you a month.
• Store, send, post or publish BHP data or proprietary
To protect against damage, loss, theft, misuse, interference • Return BHP equipment and all BHP information assets information outside of our systems or devices including
and unauthorised alteration, access and disclosure, upon termination of your employment or contract. social media without prior authorisation from your
you must safeguard and use our technology and data • Report the damage, loss or theft of BHP equipment, line leader.
securely and appropriately. or unauthorised access to, or use or disclosure of • Use non-BHP storage solutions (external hard drives,
BHP data to your line leader and Technology as quickly USBs, personal email, personal clouds or internet storage
Never use our technology or data to commit cybercrime, as possible. services) to store BHP data.
duplicate or sell software or media files, share your account
password, use data for non-BHP business purposes or cause • Protect any hardware, software and data for which you • Copy or transfer files that violate copyright laws.
reputational damage to BHP. Our technology must never are responsible from damage, loss, theft, interference • Ship our hardware or software outside of the country
be used as a platform to create or spread information that and unauthorised access, modification, disclosure of origin without engaging Technology.
is not truthful. or use.
• Disable security measures on BHP technology systems.
• Report suspicious emails to Technology as phishing.
Disciplinary action may be taken and civil or criminal • Receive compensation for the disposal of BHP equipment.
authorities notified, if you use our technology and data • Lock your screen when you are away from your
inappropriately, or inappropriate material is accessed or workstation. Our hypothetical scenarios will help you apply
stored using our systems. Inappropriate material includes Our Code every day. Scan the QR Code or go to
• Inform Workplace Technology when travelling to
pornographic or sexually explicit or exploitative images a high-risk country on BHP’s behalf to request
or text, materials promoting violence, hatred, racism, a single use device where appropriate. https://www.bhp.com/our-code-scenario13
religious beliefs, terrorism or the intolerance of others,
or any other material that is deemed obscene or abusive.
28 BHP Our Code

information
Protect our intellectual property

Intellectual property (IP) rights protect and Where new IP is created through innovations or
improvements to our processes, keep the information Never
enable our technology, processes, documents,
confidential. If you are unsure if any other protection is
products and brands. required, seek advice from Legal. Only access a third party’s • Disclose BHP’s IP without first obtaining permission
IP, if permitted in writing by that party (for example, in a from your line leader and, if the IP is confidential,
IP can cover inventions and innovations, trademarks, designs,
contract with a supplier), or otherwise as permitted by law making sure the recipient has a legal obligation to
and copyright works such as text, images, drawings and
where you have advice from Legal. Before you copy or share keep the information confidential (for example under
software, as well as confidential information (including
something provided by a third party, or develop or deploy a confidentiality agreement).
algorithms and know-how) and data. BHP both owns IP
and licenses IP from third parties. New IP is created every new technology, always check whether a third party’s • Bring to BHP or use any confidential information, including
day in our operations through copyright in new documents IP rights may be infringed. documents or computer records, from prior employers
or software code, innovations or discoveries from our or clients without their written permission.
exploration or research and development, and from working Always • Share, copy or deploy a new technology or process
with our suppliers to improve or adapt their products. without first ensuring you are not infringing a third
• Enter into a confidentiality agreement before starting party’s IP.
Like other BHP property, IP rights have financial value and
strategic value. We can stop others from copying BHP’s IP negotiations or any other engagement with a person • Use third parties’ copyright materials (for example
or we can obtain a licence to use other people’s IP in our outside BHP who may receive or access BHP’s confidential software, photographs, text, audio or video downloaded
business to gain a competitive edge. The value of our IP IP or information. from the internet) or trademarks in materials you are
can be lost by improper disclosure or use, inappropriate • Be aware of what information is confidential and comply producing including for use on BHP intranet sites,
contractual terms or failing to follow necessary formalities with BHP’s Information Protection Framework (for without first obtaining permission from the copyright
for protection, such as registration. example, classifying and marking documents). Only give or trademark owner.
confidential information to people who need to know it.
Infringing other people’s IP could result in costly legal Our hypothetical scenarios will help you apply
disputes that may impede our freedom to operate and • Ensure onboarding processes confirm ongoing
damage BHP’s reputation. confidentiality obligations and that departing
personnel have not retained any confidential materials.
What this means for you • Use BHP’s standard contracts wherever possible when
contracting with third parties, and only depart from BHP’s
You should always safeguard BHP’s IP, respect the IP rights standard IP and confidentiality terms after obtaining
of others (including suppliers and competitors) and take appropriate internal approvals.
appropriate steps to manage infringement risks. • Keep any new IP created, such as innovations or
improvements to our processes, confidential and
Never disclose BHP’s confidential information without
check with Legal if any additional protection is required.
authorisation, even if your employment or contract with BHP
has concluded. If there is a legitimate reason to share BHP’s • Ensure no third party IP rights may be infringed before
confidential information, such as where required to work you copy, share, develop or deploy new technology
with a supplier, obtain the prior approval of your line leader or processes. If unsure, seek guidance.
and a written confidentiality agreement with the other party. • Use a third party’s IP only as permitted in writing by
that party (for example in a contract with a supplier)
To protect our IP and data, use BHP’s standard contracts
or otherwise as permitted by law where you have advice
when contracting suppliers wherever possible. Follow
from Legal.
required approval processes if using any alternative terms.
BHP Our Code 29

5. Protect and
respect information
As a publicly listed company, we must comply
with regulations about sharing information.
30 BHP Our Code

information
Communicate consistently and truthfully

Engaging with our external stakeholders expect to have a material effect on the share price or value.
This includes information that would, or would be likely to, Never
in a consistent way helps build, protect
influence persons who commonly invest in securities
and enhance our reputation and licence in deciding whether to acquire or dispose of securities. • Disclose information to the public or divulge confidential
to operate, and ensures we meet our information unless you are specifically authorised to
regulatory requirements. Ensure all materials developed for external use, including do so.
speeches, articles and presentations are approved by
All public disclosures are carefully managed and can • Say anything that may disclose confidential information
Corporate Affairs.
only be made by authorised spokespeople. Any public or cause harm to our reputation.
communication that can be attributed to BHP, or to one Know how our Social Media Policy applies to you. Social • Conceal facts or omit information that may be relevant
of our employees or contractors, may be seen as a public media activity may feel casual and spontaneous however to a disclosure.
disclosure. This includes: it is permanently retained, can be traced back to you and
• Use BHP trademarks or branding unless you are
linked to BHP. When using social media, messaging
• regulatory filings, such as annual reports, stock exchange specifically authorised to do so.
or other digital channels, always do so in accordance
releases, briefings on profit and business performance with Our Charter values and Our Code. • Post content or comments in private messaging groups
• media releases, interviews, speeches, presentations, or on public social media channels that are obscene,
articles and reports defamatory, threatening, harassing, discriminatory or
Always hateful to any person, group or entity.
• digital information available on websites, social media
and messaging channels. • Follow the rules relating to who can make public
statements on behalf of BHP. Our Code every day. Scan the QR Code or go to
What this means for you • Obtain all relevant approvals prior to publicly
Always act in accordance with the Our Requirements for releasing material. https://www.bhp.com/our-code-scenario15
Market Disclosure, Our Requirements for Communications, • Report media and investor/analyst inquiries promptly
Community and External Engagement standards, to Corporate Affairs or Investor Relations.
Our Charter values, Our Code and our Social Media Policy.
• Comply with the Our Requirements for Communications,
Know and understand the difference between company Community and External Engagement standard in
information that can be shared informally (information relation to attendance at external events, presenting
that is published and in the public domain) and material speeches and participating in external
information which can only be communicated by panel discussions.
authorised BHP spokespeople. If you think you possess • Ensure anything you share on social media channels
or have released material information that has not been is publicly available information and aligns with
disclosed to the public, report it immediately to Investor Our Charter values and Our Code.
Relations, a Disclosure Officer or Group Governance.
• Immediately report any information or major
If you are an authorised spokesperson or work in a team developments that could have a material effect on the
responsible for market disclosure, you must immediately share price or investment decisions to Investor Relations,
release, through the relevant exchanges, any information a Disclosure Officer or Governance.
or major developments which a reasonable person would
BHP Our Code 31

Respect personal information and privacy
We respect your personal information and • Follow the Privacy by Design Checklist when designing
Always a new or changed processing activity that involves
privacy and expect you to respect the
personal information.
personal information and privacy of others. • Have a legal, legitimate and specific BHP business
• Immediately report any actual or suspected unauthorised
purpose for collecting, sharing, using or handling personal
Personal information is any information or opinion relating access to, modification or disclosure of, or loss, misuse
information and do not use it for any other purpose. If you
to an identified or identifiable individual (such as current, or interference of personal information to your line leader
are unsure about the purposes for which you are entitled
former or prospective employees, contractors and business and cybersecurity@bhp.com.
to collect, share, use or handle personal information, seek
contacts). This information can include names, addresses,
advice from Legal.
job applications, employment information, performance
records, health and safety information, location data, • Collect the minimum amount of personal information Never
opinions and correspondences to and from an individual. legitimately necessary for the specific business purpose.
• Access or use or share personal information without
• Maintain the accuracy of your personal information as well
More information on how we collect and process personal specific authorisation from your line leader or a clear
as any personal information that you handle or process.
information, and the rights a person has in relation to the business requirement.
personal information we hold about them is in our Global • Retain personal information for the minimum amount
• Retain personal information for longer than legally required
Privacy Notice for BHP Workers (for those who work of time necessary and securely dispose of it when it is
or necessary for the purpose it was collected (or any other
for BHP) and Privacy Policy (for all other individuals who no longer required as detailed in the Our Requirements
purpose permitted by law).
provide personal information to BHP). for Information Governance and Controlled Documents
standard. • Collect or process sensitive personal information unless
What this means for you • Notify individuals why their personal information
explicit consent has been obtained from the individual
or it is permitted by applicable laws and regulations.
is required and how it will be used and allow them
Follow our standards and procedures on handling personal to exercise their legal rights in relation to their • Store files without adequate protection and access
information and protecting privacy and only collect, use, personal information. restrictions if they contain sensitive personal information,
disclose, retain or process personal information that is such as health data or payroll information.
necessary to meet business requirements, as permitted • Adequately safeguard personal information against
by law in places where we operate. unauthorised or unlawful handling, access, use, Our hypothetical scenarios will help you apply
modification, sharing, loss, interference, destruction Our Code every day. Scan the QR Code or go to
Always treat the personal information and privacy of others or damage.
with respect. • Check and comply with the country-specific legal https://www.bhp.com/our-code-scenario16
requirements for handling personal information,
as applicable from time to time.
• Follow the Our Requirements for Information
Governance and Controlled Documents standard
when creating, capturing or managing information
including records, non-records, personal information
and controlled documents.
32 BHP Our Code

information
Report truthfully
Reporting truthfully ensures we maintain the • Cooperate with our internal and external auditors and A: ll reporting we do across the organisation should
A
trust of our stakeholders. disclose all pertinent information that could reasonably be factual and not give the impression that work
impact the data verification process and results of has been completed when it is has not, even if there
When creating and maintaining data it must be accurate, an audit. is a strong belief the work will be completed soon.
complete and appropriate. There is never a justification • Ensure no undisclosed or unrecorded account, fund
for falsifying records, misrepresenting facts or engaging or asset is established or maintained. Our hypothetical scenarios will help you apply
in any other fraudulent behaviour. All financial and non- Our Code every day. Scan the QR Code or go to
financial reports must be evidenced by appropriate source • Ensure work-related expenses are legitimate, reasonable
documents, verified for validity, accuracy and completeness, and supported by valid receipts and invoices.
properly authorised and accurately and completely recorded • Return or transfer the custody of all relevant business
in the relevant accounts, systems and records. records if you change roles within the company or
if you leave BHP. Do not keep personal copies.
What this means for you
If you are responsible for reporting financial or non-
Never
financial information, ensure you follow processes and
establish adequate internal controls to achieve truthful, • Falsify any record or make a false or misleading entry
accurate, appropriate, complete, consistent, timely and including omitting any information.
understandable reports that represent BHP and our • Circumvent review and approval procedures for reporting
business activities. Understand and comply with the Our financial or non-financial information.
Requirements standards as they apply to your role, and all
applicable financial, regulatory and reporting requirements, • Allow others to do anything that would compromise
laws and regulations in the relevant jurisdiction. the integrity of BHP’s records or reports.
• Disclose or disseminate confidential information
If you have any concerns about the validity of any reporting or competitively sensitive information without
process or record-keeping activity, or believe you are prior authorisation.
being asked to create false or misleading information,
report immediately to your 2Up, Ethics and Investigations, • Misstate your qualifications, experience or achievements.
Compliance or via EthicsPoint. • Dispose of documents and records without knowing what
is being discarded or whether they must be kept for legal
reasons.
Always
• Make and keep books, records and accounts which, Hypothetical scenario
in reasonable detail, accurately and fairly reflect BHP’s
transactions in accordance with all applicable laws, Q: I have been asked to provide a written update
regulations, standards and procedures. on the progress of one of our team’s key
• Speak up immediately if you suspect fraudulent activity improvement initiatives. We are behind schedule
and report any actual or suspected irregularities or but I know we will catch up in the next month
weaknesses in internal controls, accounting or reporting. or two. Do I need to specifically say we are
behind schedule?
BHP Our Code 33

Don’t engage in insider trading
In the course of your job, you may have access What this means for you Always
to inside information about BHP or another
company before it is made public. You are Unless you are authorised to do so, if you have inside
information you must not: • Maintain the confidentiality of BHP confidential
expected to act in accordance with legal and information and take measures to avoid accidentally
regulatory requirements or market practice. • deal in the securities of BHP (or any other company), sharing inside information.
physical commodities or commodity derivatives
Insider trading refers to trading in financial and/or physical potentially impacted. • Seek advice from Group Governance, Ethics and
markets (for example, trading shares in a company) Investigations, Compliance or Legal if you have inside
• advise, procure or encourage another person to deal information and are considering dealing in a company’s
on the basis of ‘insider information’, which may be illegal. in the securities of BHP (or any other company),
‘Inside information’ is information that is not generally relevant securities or are transacting in the physical or
physical commodities or commodity derivatives derivative commodities market and have any doubt.
available including: potentially impacted.
• the financial performance of BHP against • pass on inside information to any other person (whether
market expectations directly or indirectly) Never
• entry into or termination of a significant contract
It may also be a breach of your obligations of confidentiality • Trade relevant securities of BHP (or any other potentially
• production curtailment or shutdown to disclose confidential information, whether or not the impacted company), either directly or indirectly, while
• major strategic decisions including actual or proposed information is used to deal in the company’s relevant you are in possession of inside information.
mergers or demergers, acquisitions or divestments, securities. With specific reference to BHP securities,
if you have been placed on a Securities Dealing Restricted List • Recommend or suggest that anyone else trade in
or joint ventures
or you are a Person Discharging Managerial Responsibilities the relevant securities of BHP (or any other potentially
• actual or possible discoveries of, or significant impacted company), or transact in potentially impacted
in accordance with the Our Requirements for Securities
adjustments to ore bodies or oil reserves. financial and physical commodities markets, while you
Dealings standard, you must gain approval from a designated
Clearance Officer before engaging in any transactions are in possession of inside information.
If insider information is made publicly available, a reasonable
person would expect it to have a material effect (positive involving BHP securities. If you have been placed on such • Disclose inside information to anyone outside BHP
or negative) on the price of the particular securities and a list, then you must not deal or encourage others to deal unless you are authorised to do so.
influence an investor’s decision making. in BHP securities.
• Discuss confidential information in public or leave
If you are an employee participating in any employee share confidential information in a public place. If you
In many countries, it is a criminal offence to buy, sell or accidentally share inside information, contact
otherwise deal in securities of a company likely to be scheme (excluding Shareplus), you must not buy, sell or
otherwise deal in BHP securities during any close period, Group Governance, Ethics and Investigations,
impacted by the release of inside information. It may also Compliance or Legal immediately.
be a criminal offence to disclose inside information to regardless of whether you hold inside information.
someone else, if you suspect or have reason to believe
that the person is likely to buy, sell or otherwise deal in the Our hypothetical scenarios will help you apply
relevant securities. Under some circumstances, it is an Our Code every day. Scan the QR Code or go to
offence to buy, sell or deal in physical commodities and
commodity derivatives on the basis of insider information, https://www.bhp.com/our-code-scenario18
or encourage others to do the same.
34 BHP Our Code

bhp.com 08/22

BHP Our Code English

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

BHP Our Code English

Uploaded by

Copyright:

Available Formats

Our Code

Your guide to living

Don’t look the other way, speak up 5-7

How to speak up 8 3. Work with integrity 18-25

Foster open, constructive government relationships 19

1. Look out for one another 10-13 Manage corruption risks 20

BHP Our Code

4. Protect our company 26-29

Protect our assets 27

BHP Our Code 1

Our purpose is to bring people and resources together to build

BHP Our Code 3

4 BHP Our Code

• foster an inclusive culture where everyone feels safe

BHP Our Code 5

Nothing in Our Code, the Our Requirements standards

6 BHP Our Code

What happens if you breach Our Code?

• Be open and honest and provide as much information

• Engage in retaliation or detrimental conduct towards

BHP Our Code 7

Contact Ethics Point online via www.BHPbusinessconduct.ethicspoint.com or by phone:

Australia and Asia Europe Mexico Free call

8 BHP Our Code

BHP Our Code 9

10 BHP Our Code

A healthy and safe workplace

BHP Our Code 11

12 BHP Our Code

Behaviours that have no place at BHP

BHP Our Code 13

14 BHP Our Code

Respect human rights

BHP Our Code 15

If people raise concerns or complaints during your

16 BHP Our Code

to minimise their environmental impacts and take

BHP Our Code 17

18 BHP Our Code

Foster open, constructive government relationships

BHP Our Code 19

20 BHP Our Code

Value supplier relationships

BHP Our Code 21

22 BHP Our Code

Manage competition law risks

If you suspect an employee, contractor or third-party

BHP Our Code 23

If you are asked to withhold goods or services from a party

24 BHP Our Code

BHP Our Code 25

26 BHP Our Code

Protect our assets

You are expected to capture or create data that meets our

Never share confidential information or competitively

We are all responsible for protecting BHP’s assets and

BHP Our Code 27

28 BHP Our Code

Protect our intellectual property

BHP Our Code 29

30 BHP Our Code

Communicate consistently and truthfully

BHP Our Code 31