As a publicly listed company, we are required to disclose information in a timely, accurate, consistent, complete and fair manner so investors can make informed decisions.
We also need to apply Our Charter values to informal interactions when communicating about BHP.
To make sure we provide timely and accurate information to investors, our public disclosures are carefully managed and must only be made by authorised spokespersons. Any public communication that can be attributed to BHP, or to one of our employees, may be seen as a public disclosure.
All of the following are considered public disclosures:
- regulatory filings, such as annual reports, news releases, briefings on profit and business performance;
- interviews, speeches, presentations articles and reports;
- Company information on digital communications channels, like websites and social media.
Using social media, messaging or other digital channels
Social media, messaging apps, forums and other digital channels are important personal and business tools. They can be an invaluable way to share our values, strategy and culture with each other and the world, when done well and in line with the below guidelines.
BHP views social media activity in the same way we view any kind of interaction: through the lens of Our Charter values and Our Code of Conduct.
While using social media may feel casual and spontaneous, even private activity is permanently retained, can easily be shared by others and can be traced back to you and BHP. We want you to feel confident when you’re using social media, whether it’s to talk about BHP or in a personal capacity, to know that your activity and conversations won't land you or BHP in hot water.
How to use social media and messaging apps safely
While we encourage employees to speak about BHP, that doesn't mean you should speak for BHP. Corporate Affairs accredits certain people to speak on behalf of the company in an official capacity on particular social media platforms to ensure our stakeholders hear the right information at the right times.
BHP's Social Media Code applies to all employees, whether you are accredited or not.
- Feel free to share information about BHP but make sure it is not confidential. Confidential information includes things like movements in your team, operational issues, financial results, customer information, or commentary and more. If in doubt, check with your line manager.
- Identify yourself as a BHP employee when talking about the business so people know who they are talking to. Always make sure you talk about BHP and not on behalf of BHP.
- Make sure you’re prepared to stand behind what you post. We've seen cases where posts by BHP employees, published to a personal Facebook page, end up being shared by media organisations across the globe and are linked back to BHP. This can result in repercussions for BHP and our wider community. Think very carefully before you post.
- You are welcome to share information about BHP that is already on our website or social media channels.
- Never reveal a colleague or stakeholder's personal information on social media.
- If you see something about BHP or one of our employees or contractors on social media that you think isn't right, you can report it on Ethics Point. Also if you think that a competitor of BHP has posted information they shouldn’t have in a group of which you are a member, you should immediately report it to Legal.
- Keep it nice. It goes without saying that we won't abide any employees posting content or comments, whether in private messaging groups or on public social media channels, that are obscene, defamatory, threatening, harassing, discriminatory or hateful to any person, group or entity.
- It’s a good reminder to check that you are comfortable that what you are sharing is in line with values and our code of conduct.
If you think you possess, or have released, material information that has not been disclosed to the public, you must immediately report it to Investor Relations, a Disclosure Officer or Group Governance. Disclosure Officers should also be alerted to information that may require future disclosure to the stock exchanges. A list of Disclosure Officers is available from Group Governance.
Our expectations of youWhen you communicate externally, you should always act in accordance with Our Requirements for Market Disclosure, Our Charter values and Our Code.
If you are an authorised spokesperson or work in a team responsible for market disclosure, you must immediately release, through the relevant exchanges, any information or major developments which could have a material effect on the share price, or where an investor is likely to use that information to make investment decisions.
If you have prepared external communication materials, you must have them approved by Corporate Affairs.
It’s important you feel empowered to speak positively about BHP when asked by relatives and friends. To be able to do so, it’s important you understand the distinction between information about the Company that should be shared, and material information which can only be communicated by authorised spokespeople.
Our expectations of others who work with usThis section applies equally to those who work with us. If you have any questions or need further information please speak to your primary contact.
Where to go for help
- Corporate Affairs
- Investor Relations
- Disclosure Officer
- Governance and Company Secretariat
- Your line leader or 2Up leader
Tools and resources
- Follow the rules relating to who can make public statements on behalf of BHP.
- Ensure all public communication is complete, fair, accurate, timely and clear.
- Obtain all relevant approvals prior to publicly releasing material.
- Report media and investment inquiries promptly to Corporate Affairs or Investor Relations.
- Report the loss or theft of BHP information (for example, your computer or briefcase) to your line leader immediately.
- Advise your line leader or 2Up leader if you are attending an informal external event, such as a trade meeting or professional networking event.
- Get approval from your Business to present an external speech or participate in an external panel discussion.
- Send a copy of your speech or presentation, along with a completed ‘Speeches and presentations template’ (available in Our Requirements for Communications, Community and External Engagement), to Corporate Affairs for review and feedback.
- Disclose information to the public unless you are specifically authorised to do so.
- Divulge confidential information unless you are an authorised spokesperson. If you are unsure about the degree of confidentiality assigned to information, contact Corporate Affairs.
- Say anything that may disclose confidential information or cause harm to our reputation.
- Conceal facts or omit information that may be relevant to a disclosure.
- Use BHP trademarks or branding unless you are specifically authorised to do so.
Example questions and answers
Social mediaQuestion - I saw a comment on Facebook about something taking place at my site that I know is not accurate. Can I correct the statement?
Show AnswerIf you choose to contribute to the discussion, you should only mention information that has already been publicly shared. It’s okay to talk about your workplace, but take care not to reveal confidential information when you do. If you’re not sure, speak with your line leader first.
PhotographyQuestion - I took a great photo of my teammates on-site with our open-cut mine in the background. They are in full Personal Protective Equipment (PPE). Can I put this on Facebook?
Show AnswerEach site has its own rules around photography and you should check with your line leader on your site rules. You should also confirm with your team mates as to whether they are okay for their picture to be posted on social media.