men on site

We need to be truthful in all our reporting to make sure we maintain the trust of our stakeholders and our social licence to operate.

All data we create and maintain must accurately reflect the underlying transactions and events. There is never a justification for falsifying records, misrepresenting facts or engaging in any other fraudulent behaviour.

All financial transactions must be evidenced by appropriate source documents, verified for their validity and accuracy, properly authorised and accurately and completely recorded in the relevant accounts, systems and records. This includes, but is not limited to, bid and tender evaluation records, purchase orders, maintenance reports, receiving documents, invoices, travel and expense records, journal entries, timesheets and tax filings.

Expectations and resources



  • Cooperate with our internal and external auditors and disclose all pertinent information that could reasonably impact the results of an audit.
  • Report any actual or suspected irregularities or weaknesses in relation to internal controls, accounting or reporting.
  • Speak up immediately about any suspicions of fraud.
  • Keep accurate, complete and true Company books, records, accounts, documentation and reports in accordance with applicable laws, regulations, standards and procedures.
  • Protect BHP records from unauthorised access, change, dissemination or destruction.
  • Accurately record work time relating to BHP and all leave taken.
  • Make sure no undisclosed or unrecorded account, fund or asset is established or maintained.
  • Make sure you only submit and approve legitimate and reasonable expenses that are supported by valid receipts and invoices.
  • Return or transfer the custody of all relevant business records if you change your job within the Company or if you leave BHP. Do not keep personal copies.


  • Falsify any record or make a false or misleading entry including omitting any information.
  • Misstate your qualifications, experience or achievements.
  • Circumvent review and approval procedures.
  • Allow others to do anything that would compromise the integrity of BHP’s records or reports.
  • Allow someone else to log on and operate systems and applications using your ID and user access rights.
  • Disclose or disseminate confidential or commercially sensitive information without prior authorisation.
  • Dispose of documents and records without knowing what is being discarded or whether they must be kept for legal reasons.

Example questions and answers

Third party individual with checklist

Accidents and near misses

Question - During my last shift my vehicle collided with another vehicle while going around a bend. We both reacted quickly, there was no damage to either vehicle and neither of us were hurt. Do we have to take time out from our jobs to fill out paperwork and report this as nothing happened?
  • Show Answer

    We all have a duty of care to report all accidents and near misses. While in this instance no one was injured, next time it could be more serious. It’s important that all near misses are reported so they can be appropriately investigated and safety measures put in place to prevent a more serious outcome.

Office employee at desk


Question - I am responsible for approving expense reports for my team. I have six direct reports and some months I don’t have time to check to make sure receipts are attached but I trust my team. Do I need to review every receipt?
  • Show Answer

    As a line leader you have an additional duty of care to be a positive and visible role model. Whenever you approve anything in the system — whether an expense report, service entry sheet, goods receipt or otherwise — it is important that you verify that the underlying transaction is appropriate. It is not undermining the trust you have in your team but a requirement that we have receipts for all our expenses. You should be checking that the expenses incurred are work related and copies of all receipts have been attached.

 Report a concern


In person: Speak to your line leader, 2Up leaders or Human Resources representative


Online: EthicsPoint Online

Phone: EthicsPoint Telephone


BHP Business Conduct,
GPO Box 86,
Victoria 3001, Australia