man on bridge

Our business involves international trade. We respect the international trade laws that govern these transactions and comply with all applicable export controls and sanctions.

Governments implement trade control laws to support their foreign policy and national security objectives. If we are involved in a transaction that breaches these laws, it may expose us and our employees to criminal penalties and cause significant damage to our reputation. These laws include trade sanctions, export controls and anti-boycott laws.

Expectations and resources

  • Our expectations of you
    BHP screens suppliers and customers to block transactions with sanctioned countries and sanctioned parties. If you are involved in international transactions or may interact with individuals or entities who are subject to sanctions, you need to comply with our screening procedures. Check with Ethics and Compliance before proceeding as sanctions programs are subject to frequent change. Examples of countries affected by comprehensive sanctions at time of publication included Crimea (Region of the Ukraine), Cuba, Iran, North Korea and Syria. If you become aware of any activity involving BHP and any of these countries or their citizens, you must contact Ethics and Compliance immediately.

    Before sending technical information, software or equipment across international borders, check that you are legally allowed to do so. Seek assistance from Ethics and Compliance and allow enough time to obtain any licences that may be required.

    If you are asked to withhold goods or services from a party because of their race, religion, gender, national origin or nationality, contact Ethics and Compliance about how to respond.
  • Our expectations of others who work with us
    When you work on behalf of BHP, we expect that you will respect all international trade laws of the countries in which we operate.
  • Where to go for help
    • Ethics and Compliance
    • Legal
    • Your line leader or 2Up leader
    • EthicsPoint
  • Tools and resources

Guidance


Always

  • Make sure that accurate and complete information is provided to government authorities, including on import and export declarations.
  • Know your counterparty and follow Finance approval processes.
  • Understand the routes that are being used to transfer information, goods and services between locations, and identify borders that are being crossed.
  • Understand whether your counterparty is on-selling goods and get assurances to avoid on-selling to a sanctioned party.
  • Understand whether your counterparty is using BHP products to produce goods destined for a sanctioned party or country – your counterparty may not be subject to the same sanctions programs.
  • Get the necessary approvals and licenses before proceeding with a transaction.
  • Understand whether your nationality or citizenship affects your ability to be involved in an international transaction.

Never

  • Undertake any business activity with a party who has been identified as sanctioned in our screening or from a sanctioned country without prior approval from Ethics and Compliance.
  • Proceed with a business transaction if there is any doubt about whether the transaction might breach trade controls laws without prior approval from Ethics and Compliance.
  • Allow a transaction to proceed with a counterparty that is intended to conceal the identity of the true counterparty.

Example questions and answers

Working with other countries

Question:  I am an Australian employee working in Singapore and have a US green card. I hear that some companies are starting to investigate opportunities for marketing our products in Iran and would like to do some exploratory work. I thought that I would call the Iranian trade promotion agency to start the ball rolling.
  • Show Answer
    Some countries have relaxed their sanctions against Iran and this has allowed companies from those countries to enter the Iranian market. However, Iran is still the subject of comprehensive sanctions in the United States. You must seek advice from Ethics and Compliance before taking any steps, especially as you have a personal connection with the United States.

Signing documents

Question: I have been involved in the engineering design for a development project in Chile and am interested in purchasing drones from the US to conduct testing at site. I have also received a document from a French vendor for my signature confirming that BHP will comply with export control requirements following receipt of a part.
  • Show Answer
    The technology utilised by drones may be subject to export controls restrictions. You must understand the nature of documents that you sign at a vendor’s request. In this case, BHP may be assuming significant ongoing obligations under export controls laws. In both instances, you must always contact Ethics and Compliance to get necessary approvals and licences before proceeding.

 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

Mail

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