Our commitment to operating with integrity is part of who we are and what we do every day. We prohibit bribery and corruption in all our business.

How we go about our business matters. Corruption misallocates resources, reinforces poverty, undermines the integrity of government and community decision making, and results in waste of the opportunities that arise from resource development.

Compliance with anti-corruption laws is essential to protect BHP’s reputation and to preserve our licence to operate. All our employees, contractors, directors (executive and non-executive) of our Boards, and third parties we deal with, including our suppliers, are required to comply with anti-corruption laws. No one has the authority to waive this requirement. Criminal penalties could result where anti-corruption laws are not respected.

Any concerns regarding corruption must be reported immediately.

Expectations and resources

  • Our expectations of you
    Our Requirements for Business Conduct provides guidance about managing corruption risk.

    You must not authorise, offer, give or promise anything of value, directly or indirectly (for example, through a third party), to anyone to influence them in their role, or to encourage them to perform their work disloyally or improperly.

    You should never make facilitation payments which are payments to government officials for routine services that are legally available. However, a payment made in the face of a threat to the health or safety of a person is not a facilitation payment. You should always act in a manner that best protects your health and safety. If you do make a health and safety payment, report it to Ethics and Compliance as soon as possible.

    You must get pre-approval before:
    • offering anything of value to an external person;
    • engaging a supplier who will interact with others on our behalf;
    • offering to undertake a community donation or project;
    • offering to sponsor an event.

    When you offer or provide anything of value to an external person, the item must:

    • only be offered or provided for a legitimate business purpose;
    • not be offered or provided to improperly influence or reward action;
    • be legal under local laws;
    • be of appropriate value and nature considering local customs and law, the position of the recipient and the circumstances;
    • not be capable of causing reputational damage to BHP.
  • Our expectations of others who work with us
    We expect everyone who works with us to share our commitment to integrity in all business dealings and in providing services to us.
  • Where to go for help
    • Ethics and Compliance
    • Legal
    • Your line leader or 2Up leader
    • Human Resources
    • EthicsPoint
  • Tools and resources




  • Record all transactions accurately and in reasonable detail to reflect their true nature.
  • Understand the role and interests of the person who you are dealing with.
  • Provide accurate and complete information when seeking pre-approval.
  • Get pre-approval before offering or giving anything of value, a commercial sponsorship or a community donation or project.
  • Act in the best interests of your health and safety.
  • Immediately report any corruption concerns.


  • Offer, promise, give or approve anything of value (including a daily allowance or per diem, cash or cash equivalent) of any kind to a government official to influence official action, including facilitation payments without prior authorisation from Ethics and Compliance. This also applies to a political party, elected official or candidate for public office.
  • Offer, promise, give or approve schemes which give an improper benefit to anyone.
  • Establish a hidden or incorrectly recorded fund for prohibited payments.
  • Use personal funds, divide payments, or hide activity which would otherwise need pre-approval.
  • Use a supplier if you are concerned they will engage in corrupt or improper conduct on our behalf.

Example questions and answers


Question: I have recently arrived in a new city on an assignment. There is a business association which seems to have good access to local officials and I have obtained approval to join. One of the association’s officials approaches me about sponsoring a table for their annual dinner — tickets are $1,000 per head. The association will use profits from the event to fund their annual golf event for local officials. Can I sponsor a table?
  • Show Answer
    Ask yourself whether there is a legitimate business purpose and whether the cost is reasonable for a meal in this location. In this instance, the proposed use of the funds for a golf event indicates that the funds will be used to provide something of value to officials. Pre-approvals will be required under Our Requirements for Business Conduct and Ethics and Compliance can advise you on what arrangements would be appropriate.


Question: I speak regularly with a government official who is responsible for making decisions that will affect BHP. After one meeting, he tells me that his son has recently graduated with first class honours from university at a location where BHP has an office. His son wants to find a job at that location so that he can stay on in the country. The official asks if BHP has any jobs and whether I can do anything to help her son.
  • Show Answer
    A job is something of value and the son is a close relative of an influential government official. Given the official is currently making decisions which will affect BHP, this could be a breach of anti-corruption laws. You should say that you cannot offer personal assistance. The official’s son can apply for advertised jobs and his application will be assessed on its merits in the same manner as any other job application. Further advice is available from Human Resources and Ethics and Compliance.

 Report a concern


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

Email: Ethics.Team@bhp.com

Online: EthicsPoint Online

Phone: EthicsPoint Telephone


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